United States Tax Court February 3, 2004, No. 9160-02 (Fla. Country Clubs, Inc. v. Comm'r)

lead-opinion

OPINION

KROUPA, Judge:

This matter is before the Court on respondent’s motion for summary judgment under Rule 121.1 The sole issue for decision is whether petitioners are entitled to reasonable administrative costs under section 7430 for expenses incurred in proceedings within the Internal Revenue Service (IRS) regarding their 1993 and 1994 Federal income taxes.