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BALL v. COMMISSIONER

Docket No. 1647-93.

70 T.C.M. 1132 (1995)

T.C. Memo. 1995-520

James L. Ball v. Commissioner.

United States Tax Court.

Filed October 31, 1995.

Attorney(s) appearing for the Case

Thomas F. Kelly, Kirkland, Wash., for the petitioners. John M. Altman, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

COLVIN, Judge:

The sole issue for decision is whether petitioner is entitled to an award of reasonable administrative costs under section 7430(c) with respect to his 1984, 1985, and 1986 Federal income taxes.1 The parties submitted the case fully stipulated under Rule 122.

Section references are to the Internal Revenue Code of 1986 as in effect in 1990. Rule references are to the...

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