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HUFFMAN v. C.I.R.

Nos. 91-70331, 91-70423.

978 F.2d 1139 (1992)

Clair S. HUFFMAN; Estate of Patricia C. Huffman, Deceased, Clair S. Huffman, Executor, Petitioners/Appellants/Cross-Appellees, v. COMMISSIONER OF INTERNAL REVENUE, Respondent/Appellee/Cross-Appellant.

United States Court of Appeals, Ninth Circuit.

Decided November 4, 1992.

As Amended December 4, 1992.

Attorney(s) appearing for the Case

Kevin G. Staker, Gregory R. Gose, Philip G. Panitz, Steven L. Staker, Law Offices of Staker and Gose, Camarillo, Cal., for petitioners/appellants/appellees.

Gilbert S. Rothenberg, Gary R. Allen, Kimberly S. Stanley, Tax Div., Dept. of Justice, Washington, D.C., for respondent/appellee/appellant.

Before: SNEED and D.W. NELSON, Circuit Judges, and WANGER, District Judge.

WANGER, District Judge:

Petitioners, Clair S. Huffman and his wife, Patricia S. Huffman, now deceased, appeal from the Tax Court's partial grant of their motion for costs and attorney's fees requested under I.R.C. § 7430, as amended by the Technical and Miscellaneous Revenue Act of 1988, Pub.L. No. 100-647, 102 Stat. 3342, § 6239(a) ("TAMRA"), which allows the recovery of "reasonable administrative costs" and "reasonable litigation costs" by a prevailing...

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