Legal Opinion

Bragg v. Commissioner

United States Tax Court

Decided May 24, 1994No. Docket No. 18827-90Published

Ps filed a motion for an award of reasonable litigation costs in connection with the underlying case, Bragg v. Commissioner, T.C. Memo. 1993-479. In Bragg there were seven issues for our consideration.

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Ps filed a motion for an award of reasonable litigation costs in connection with the underlying case, Bragg v. Commissioner, T.C. Memo. 1993-479. In Bragg there were seven issues for our consideration. Of these seven issues, Ps narrowly prevailed with respect to one issue, partially prevailed on another, and simply lost the remaining five. 1. Held, Ps' motion for an award of reasonable litigation costs is denied. 2. Held, further: In the exercise of the Court's discretion, no sanction will be imposed on Ps' counsel under sec. 6673(a)(2), I.R.C. It is the filing of this type of motion, one…

1Opinion of the Court

Jackson B. Bragg and Suzanne Bragg, Petitioners v. Commissioner of Internal Revenue, Respondent

Bragg v. Commissioner

Docket No. 18827-90

United States Tax Court

102 T.C. 715; 1994 U.S. Tax Ct. LEXIS 35; 102 T.C. No. 32;

May 24, 1994, Filed

An appropriate order and decision will be entered.

Ps filed a motion for an award of reasonable litigation costs in connection with the underlying case, Bragg v. Commissioner, T.C. Memo. 1993-479. In Bragg there were seven issues for our consideration. Of these seven issues, Ps narrowly prevailed with respect to one issue, partially prevailed on another, and…

2Cases cited11 opinions

  1. Sher v. CommissionerUnited States Tax Court · 1987
  2. Leopold Z. Sher and Karen B. Sher v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
  3. Sokol v. CommissionerUnited States Tax Court · 1989
  4. Robert Randall Baker v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1986
  5. Baker v. CommissionerUnited States Tax Court · 1984

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