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GLADDEN v. COMMISSIONER

Docket No. 16932-97.

120 T.C. 446 (2003)

120 T.C. No. 16

WILLIAM T. GLADDEN AND NICOLE L. GLADDEN, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 27, 2003.

Attorney(s) appearing for the Case

William L. Raby, for petitioners.

Rachael J. Zepeda, for respondent.

SUPPLEMENTAL OPINION

SWIFT, Judge:

This matter is before us on petitioners' motion for partial summary judgment as to the applicability of the qualified offer provision of section 7430(c)(4)(E). Petitioners seek a recovery of litigation costs relating to a Federal income tax deficiency adjustment determined by respondent with respect to income to be charged to petitioners on termination of water rights (water rights adjustment).

Unless otherwise...

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