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DON CASEY CO. v. COMMISSIONER

Docket No. 42107-84.

87 T.C. 847 (1986)

DON CASEY CO., INC.; CHARLES DON CASEY, SOLE SHAREHOLDER OF DON CASEY CO., INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed October 28, 1986.

Attorney(s) appearing for the Case

Howard A. Weinberger, for the petitioner.

William P. Hardeman, for the respondent.

OPINION

SIMPSON, Judge:

This matter is now before us on a motion by the petitioner for reimbursement of its litigation costs under section 7430 of the Internal Revenue Code of 1954.1 The principal issue for decision is whether the Commissioner was unreasonable within the meaning of that section in pursuing the litigation in this Court.

The petitioner, Don Casey Co., Inc. (the company), was a Texas corporation with...

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