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HAAS & ASSOCIATES ACCOUNTANCY CORP. v. CMMR.

Docket Nos. 16486-98, 16487-98.

117 T.C. 48 (2001)

117 T.C. No. 5

HAAS & ASSOCIATES ACCOUNTANCY CORPORATION, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT MICHAEL A. HAAS AND ANGELA M. HAAS, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed August 10, 2001.

Attorney(s) appearing for the Case

William Edward Taggart, Jr., for petitioners.

Kathryn K. Vetter, for respondent.

SUPPLEMENTAL FINDINGS OF FACT AND OPINION

SWIFT, Judge:

This matter is before us on petitioners' motion under Rule 231 for an award of $44,559 in litigation costs and fees under the general provisions of section 7430 and under the qualified offer rule of section 7430(c)(4)(E) and (g).

In these consolidated cases, respondent determined deficiencies in petitioners' Federal income taxes and accuracy-related penalties as follows:

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