Nguyen v. Commissioner of Internal Revenue T.C. Memo (2003-313)

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Background

Nguyen v. Commissioner T.C. Memo (2003-313)

This is a memorandum from the U.S. Tax Court.  Nguyen filed an tax return for the year 2000 and also claimed a tax refund for $4098.  In response to a selection for examination, Nguyen sent various documents to the respondent.  The respondent stated this information was insufficient and issued another letter to Nguyen for more information.

The issues for decision in this case are as follows:

  1. Whether the IRS’s position in the administrative and court proceedings was substantially justified.
  2. Whether Nguyen unreasonably extended the administrative and court proceedings.
  3. Whether the administrative and litigation costs claimed by Nguyen are reasonable.

Basic Facts

Taxpayers are required to provide information in regards to deductions and claims  by maintaining records necessary to establish both the taxpayers’ entitlement to such items and the proper amount.  This case dealt with research credits, child tax credit, income credit and  The Court holds that respondent’s position in the administrative and court proceedings was substantially justified because failed to substantiate their claims with appropriate information. The Opinion has considered other arguments made by petitioner for a contrary result and found those arguments to be without merit.

Findings

Nguyen is not entitled to administrative and litigation costs.

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