Sokol v. Commissioner
United States Tax Court
Prior to filing his answer to the petition herein, R tried to concede the tax issue raised in the deficiency notice and in the petition. Ps refused to execute a stipulated decision document because R would not concede Ps' entitlement to litigation costs under sec. 7430, I.R.C. 1954. In his answer to the petition, R conceded the only tax issue raised in the deficiency notice and in the petition.
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Prior to filing his answer to the petition herein, R tried to concede the tax issue raised in the deficiency notice and in the petition. Ps refused to execute a stipulated decision document because R would not concede Ps' entitlement to litigation costs under sec. 7430, I.R.C. 1954. In his answer to the petition, R conceded the only tax issue raised in the deficiency notice and in the petition. No further action was taken by either party until the case was called from a trial calendar for trial, at which time the parties filed a stipulation that there was no deficiency in or overpayment of…
1Opinion of the Court
Parker, Judge:
This case is before the Court on petitioners’ motion for litigation costs under section 7430.1 Specifically, the issue is whether respondent’s position in this civil proceeding was unreasonable within the meaning of section 7430(c)(2)(A)(i) [now section 7430(c)(4)(A)(i)].
FINDINGS OF FACT2
At the time the petition was filed, petitioners resided in St. Joseph, Missouri. Petitioner Ronald M. Sokol (Mr. Sokol) is an attorney, now employed by his professional corporation, Ronald M. Sokol, P.C. Ronald M. Sokol, P.C. was incorporated on November 5, 1981. In addition to petitioners’…
2Cases cited29 opinions
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- 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
- Wasie v. CommissionerUnited States Tax Court · 1986
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