1. Home
  2. Browse Decisions
  3. T.C.M.
  4. 66 T.C.M.
  5. 66 T.C.M. 1852 (1993)
 

CONNELL v. COMMISSIONER

Docket No. 28893-88.

66 T.C.M. 1852 (1993)

T.C. Memo. 1993-638

Marjorie E. Connell v. Commissioner.

United States Tax Court.

Filed December 29, 1993.

Attorney(s) appearing for the Case

Charles Wist, 11111 Katy Frwy., Houston, Tex., for the petitioner. David H. Peck and William G. Bissell, for the respondent.

Memorandum Opinion

COLVIN, Judge:

This matter is before the Court on petitioner's motion for litigation costs under section 7430 and Rule 231.1 After concessions, the sole issue we must decide is whether petitioner has shown that respondent's position in this proceeding was not substantially justified within the meaning of section 7430(c)(2)(A)(i). We hold that petitioner has failed to do so.

We previously held that the...

Let's get started

Leagle.com

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.

  • Updated daily.
  • Uncompromising quality.
  • Complete, Accurate, Current.

Listed below are the cases that are cited in this Featured Case. Click the citation to see the full text of the cited case. Citations are also linked in the body of the Featured Case.

Cited Cases

  • No Cases Found

Listed below are those cases in which this Featured Case is cited. Click on the case name to see the full text of the citing case.

Citing Cases