ROONEY v. COMMISSIONER

Docket No. 9470-90.

63 T.C.M. 1905 (1992)

T.C. Memo. 1992-47

Frances K. Rooney v. Commissioner.

United States Tax Court.

Filed January 27, 1992.


Attorney(s) appearing for the Case

Jerry S. Goldman, 1411 Walnut St., Philadelphia, Pa., for the petitioner. Michael D. Baker, for the respondent.


Memorandum Opinion

PATE, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b).1 It is before the Court on petitioner's Motion for Award of Reasonable Litigation Costs filed May 19, 1991. The issues for our decision are: (1) Whether petitioner is entitled to an award of litigation costs and, if so, (2) the amount to be awarded.

Petitioner did not timely file Federal income tax returns...

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