Coastal Petroleum Refiners, Inc. v. Commissioner
United States Tax Court
Prior to trial, R conceded two of the issues raised in the petition. After the trial, but before either party had filed opening briefs, R conceded the remainder of the case. P subsequently filed a motion for litigation costs pursuant to Rule 231, Tax Court Rules of Practice and Procedure, and sec. 7430, I.R.C. 1954. Held: Considering the facts presented in the record, R's position was not unreasonable. P's motion for litigation costs is denied.
1Opinion of the Court
OPINION
RUWE, Judge:
Petitioner is a corporation organized and existing under the laws of the State of California. At the time the petition was filed, petitioner had its principal office at 14711 Bentley Circle, Tustin, California.
On July 3, 1985, respondent mailed a notice of deficiency to petitioner determining deficiencies and an addition to tax as follows:
TYE Deficiency Sec. 6653(b)
1/31/80 $38,663
1/31/81 552,926 $276,463
TYE Deficiency Sec. 6653(b)(1)
1/31/82 $181,326
Prior to the trial of this case, respondent conceded two of the four basic issues. Subsequent to trial, and prior to the filing…
2Cases cited22 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- 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
- De Venney v. CommissionerUnited States Tax Court · 1985
- Sokol v. CommissionerUnited States Tax Court · 1989
17 more not listed; retrieve them via the Exa API.
3Cited by56 opinions
- MAGGIE MGMT. CO. v. COMMISSIONER OF INTERNAL REVENUEUnited States Tax Court · 1997
- Bragg v. CommissionerUnited States Tax Court · 1994
- Bayer v. CommissionerUnited States Tax Court · 1991
- Beecroft v. CommissionerUnited States Tax Court · 1997
- Schlicher v. CommissionerUnited States Tax Court · 1997
51 more not listed; retrieve them via the Exa API.