Fla. Country Clubs, Inc. v. Comm'r
United States Tax Court
Petitioners (Ps), two S corporations and two shareholders of those corporations, received letters of proposed deficiency with respect to their 1993 and 1994 Federal income tax returns, which allowed Ps an opportunity for administrative review in Respondent's (R) Appeals Office. After Ps protested the proposed deficiencies with the Appeals Office, the parties settled without R's issuing either an Appeals Office notice of decision or a notice of deficiency.
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Petitioners (Ps), two S corporations and two shareholders of those corporations, received letters of proposed deficiency with respect to their 1993 and 1994 Federal income tax returns, which allowed Ps an opportunity for administrative review in Respondent's (R) Appeals Office. After Ps protested the proposed deficiencies with the Appeals Office, the parties settled without R's issuing either an Appeals Office notice of decision or a notice of deficiency. Ps filed a petition with this Court under sec. 7430(f), I.R.C., and Rule 271, Tax Court Rules of Practice and Procedure, for reasonable…
1Opinion of the Court
OPINION
KROUPA, Judge:
This matter is before the Court on respondent’s motion for summary judgment under Rule 121.1 The sole issue for decision is whether petitioners are entitled to reasonable administrative costs under section 7430 for expenses incurred in proceedings within the Internal Revenue Service (IRS) regarding their 1993 and 1994 Federal income taxes. For the reasons explained below, we find that petitioners are not entitled to administrative costs.
Background
Petitioners are James R. Mikes (Mikes), Deborah A. Hamilton (Hamilton), Florida Country Clubs, Inc. (FCC), and Suncoast Country…
2Cases cited24 opinions
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- Russello v. United StatesSupreme Court of the United States · 1983
- Keene Corp. v. United StatesSupreme Court of the United States · 1993
- Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
- Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992
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