§74302
9 cases·4 followed·1 overruled·4 cited—44% support
Statute Text — 26 U.S.C. §74302
Statute text not available for this section.
9 Citing Cases
Held: R's general objections to the motion to compel are overruled.
- 3 - administrative costs pursuant to section 74302 and Rule 231.3 The issues for decision are: (1) Whether Sandra is the “prevailing party” for purposes of section 7430--in particular: (A) Whether respondent established that respondent’s position was “substantially justified”, within the meaning of section 7430(c)(4)(B)(i), or (B) Whether Sandra submitted a “qualified offer” withing t
- 2 - costs pursuant to section 74302 and Rule 231.
OPINION Requirements Under Section 74302 Under section 7430(a), a judgment for costs incurred in an administrative proceeding in connection with the determination of any tax may be awarded only if a taxpayer: (1) Is the "prevailing party"; and (2) did not unreasonably protract the administrative proceeding.
- 2 - administrative costs under section 74302 and Rule 231.
- 2 - administrative costs under section 74302 and Rule 231.
- 2 - administrative costs under section 74302 and Rule 231.