The entire 27 page Tax Court Opinion can be found @ http://www.ustaxcourt.gov/InOpHistoric/KINGSTON.TCM.WPD.pdf NOTE: The Adobe Acrobat Reader Program is required to view the decision, it is available free of charge, the link can be found at the end of this page.
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The following is a portion of the Tax Court's Decision on my Motion for an Award of Litigation Costs, published by CCH as TCM 1998-119.
U.S. Tax Court agreed with me, that the IRS's position "was not substantially justified", "had no basis in fact or law" and "was in direct conflict with the legal precedent that actually controlled the dispute". I was awarded out-of-pocket litigation cost. 100s of taxpayer in this same partnership, paid taxes, interest and penalties they did not owe... was it due to improper representation or a fear to fight the IRS?
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