Powers v. Commissioner
United States Tax Court
This case is before the Court on P's motion for litigation costs under sec. 7430, I.R.C. P owned five office building complexes during the years at issue. He claimed $ 1,452,854 in deductions in 1978 and $ 4,874,239 in 1979. At R's request, P timely signed Forms 872-A to extend the time to assess tax for his 1978 and 1979 returns.
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This case is before the Court on P's motion for litigation costs under sec. 7430, I.R.C. P owned five office building complexes during the years at issue. He claimed $ 1,452,854 in deductions in 1978 and $ 4,874,239 in 1979. At R's request, P timely signed Forms 872-A to extend the time to assess tax for his 1978 and 1979 returns. Other than asking P to sign the Forms 872-A, R did not contact P or audit his 1978 or 1979 returns during the almost 3 years after they were filed, or during the 3 years after P signed the Forms 872-A. Before asking P to sign the Forms 872-A, R had decided not to…
1Opinion of the Court
Colvin, Judge:
This case is before the Court on petitioner’s motion for award of reasonable litigation costs pursuant to section 7430 and Rule 231.
Respondent determined that petitioner was liable for: (1) Deficiencies of $496,054 for 1978 and $1,288,316 for 1979; (2) additions to tax for negligence under section 6653(a) of $24,803 for 1978 and $64,416 for 1979; and (3) increased interest for tax-motivated transactions under section 6621(d). When the case was settled, the total amount in dispute was $7,145,266.71. In that settlement, respondent conceded that no deficiency was due.
We must decide…
2Cases cited77 opinions
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