Legal Opinion

Fla. Country Clubs, Inc. v. Comm'r

United States Tax Court

Decided February 3, 2004No. 9160-02PublishedCited by 37 opinions

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

  1. Immigration & Naturalization Service v. Cardoza-FonsecaSupreme Court of the United States · 1987
  2. Russello v. United StatesSupreme Court of the United States · 1983
  3. Keene Corp. v. United StatesSupreme Court of the United States · 1993
  4. Sundstrand Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Seventh Circuit · 1994
  5. Sundstrand Corp. v. CommissionerUnited States Tax Court · 1992

19 more not listed; retrieve them via the Exa API.

3Cited by37 opinions

  1. Lantz v. Comm'rUnited States Tax Court · 2009
  2. Samueli v. Comm'rUnited States Tax Court · 2009
  3. Larson v. United StatesUnited States Court of Federal Claims · 2009
  4. Severo v. Comm'rUnited States Tax Court · 2007
  5. Mohamed v. Comm'rUnited States Tax Court · 2012

32 more not listed; retrieve them via the Exa API.

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