Bragg v. Commissioner
United States Tax Court
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.
Read the full summary
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
OPINION
Wright, Judge:
This matter is before the Court on petitioners’ motion for an award of reasonable litigation costs under Rule 231 and section 7430.1 The merits of the underlying case were decided in Bragg v. Commissioner, T.C. Memo. 1993-479, filed October 18, 1993, and to the extent necessary for the disposition of this motion, the facts and holdings in T.C. Memo. 1993-479 are incorporated by this reference.
For taxable year 1985, the issues for decision were: (1) Whether petitioners were entitled to a claimed charitable contribution deduction under section 170 in the amount of $145,000…
2Cases cited10 opinions
- Sher v. CommissionerUnited States Tax Court · 1987
- Leopold Z. Sher and Karen B. Sher v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Sokol v. CommissionerUnited States Tax Court · 1989
- Robert Randall Baker v. Commissioner of Internal RevenueCourt of Appeals for the D.C. Circuit · 1986
- Baker v. CommissionerUnited States Tax Court · 1984
5 more not listed; retrieve them via the Exa API.
3Cited by9 opinions
- Goettee v. Comm'rUnited States Tax Court · 2005
- Brinson Company-Midwest v. CommissionerUnited States Tax Court · 1996
- Mosteirin v. CommissionerUnited States Tax Court · 1995
- Bragg v. CommissionerUnited States Tax Court · 1994
- Evans v. CommissionerUnited States Tax Court · 1999
4 more not listed; retrieve them via the Exa API.