Maggie Management Company v. Commissioner

OPINION

NlMS, Judge:

This matter is before the Court on petitioner’s motion for an award of reasonable litigation and administrative costs (motion for costs) filed pursuant to Rule 231 and section 7430 on January 2, 1997. Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. All section references are to sections of the Internal Revenue Code in effect at the time the petition was filed.

Respondent issued a statutory notice of deficiency on February 14, 1994, in which deficiencies in income tax and additions to tax were determined as follows:

Addition…