Comtec Sys. v. Commissioner

COMTEC SYSTEMS, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Comtec Sys. v. Commissioner

Docket No. 24015-91

United States Tax Court

T.C. Memo 1995-310; 1995 Tax Ct. Memo LEXIS 309; 70 T.C.M. (CCH) 52;

July 13, 1995, Filed

For petitioner: Magda Abdo-Gomez.

For respondent: Avarian R. McKendrick and Ellen T. Friberg.

COLVIN

COLVIN

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge: This matter is before the Court on petitioner's motion for litigation costs under section 7430 and Rule 231.

To prevail, petitioner must show that respondent's position in the underlying litigation was not…