Polyco, Inc. v. Commissioner
United States Tax Court
Held: Reasonable litigation costs denied because petitioner failed to exhaust administrative remedies, failed to show that it was the prevailing party in that it met the requirements of tit. 5, sec. 504(b)(1)(B), United States Code, and unduly protracted these proceedings.
1Opinion of the Court
OPINION
WHITAKER, Judge:
This cause was set for trial on June 6, 1988, on the Court’s regular trial calendar held in Dallas, Texas. On that day, the parties filed a stipulation of settlement and a stipulated decision. The decision was entered on June 14, 1988. On July 18, 1988, petitioner filed a motion for reasonable litigation costs and on July 28, 1988, a motion to vacate decision. On August 31, 1988, respondent filed notice of objection to each of petitioner’s two motions.
At the suggestion of the Court, on September 30, 1988, petitioner filed an amended affidavit in support of its motion…
2Cases cited4 opinions
- Sher v. CommissionerUnited States Tax Court · 1987
- De Venney v. CommissionerUnited States Tax Court · 1985
- Senate Realty Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1975
- Pulitzer v. CommissionerUnited States Tax Court · 1987
3Cited by34 opinions
- Powers v. CommissionerUnited States Tax Court · 1993
- Gantner v. CommissionerUnited States Tax Court · 1989
- MAGGIE MGMT. CO. v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 1997
- Cassuto v. CommissionerUnited States Tax Court · 1989
- Dixson Int'l Service Corp. v. CommissionerUnited States Tax Court · 1990
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