Terrell Equipment Co. Inc. v. Commissioner

WIENER, Circuit Judge:

After a jury acquitted Petitioner-Appellant Vernon Griffin on all charges of criminal tax fraud (evasion), Respondent-Appel-lee Commissioner of Internal Revenue (“Commissioner”) assessed deficiencies, additions to tax, and penalties against all Petitioners-Appellants (“Petitioners” or “taxpayers”) for the tax years 1987, 1988, and 1989, the same years involved in the criminal case. The taxpayers challenged that determination in the United States Tax Court (“Tax Court”) and ultimately prevailed. Petitioners then moved for an award of attorneys’ fees and costs pursuant to…