| Internal Revenue Service |
Department of the Treasury |
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| Date: |
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Person to Contact: |
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Employee Identification Number: |
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Telephone Number: |
| (Name and Address) |
Fax Number: |
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Refer Reply to:
AP::
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In Re: |
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Tax Period(s) Ended: |
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| Dear |
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| We completed our review of your claim for administrative costs under Section 7430 of the Internal Revenue Code. We have fully
disallowed your claim because:
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| (Additional Paragraph Selections) |
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For costs incurred after January 18, 1999, you didn't incur the costs on the earliest of: (1) after the date on which we sent
the first letter of proposed deficiency which allows the taxpayer an opportunity for administrative review in the IRS office
of Appeals, (2) after the date you received the Appeals decision letter, or (3) the date of the notice of deficiency.
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For costs incurred between November 11, 1998 and January 18, 1999, you didn't incur the costs on or after the date you received
the Appeals decision letter or the date of our notice of deficiency, whichever is earlier.
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You incurred the costs before November 11, 1988. |
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You didn't substantially prevail on the amount in controversy or on the most significant tax issue or issues in question.
(This means that you didn't establish that your position was correct on the amount in question or the most important issues.)
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You can't be treated as the prevailing party since the IRS has established that its position was substantially justified as
of the date you incurred the costs.
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You didn't establish that you met the net worth and size limitations described below, for claiming administrative costs. For individual and estate taxpayers:
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Your net worth must not exceed $2 million. For estate taxpayers, the decedent's net worth must not exceed $2 million as of
the date of the decedent's death. Charities and certain cooperatives: You must not have more than 500 employees. For all taxpayers other than the two categories listed above: Your net worth must not exceed $7 million, and you must not have more than 500 employees.
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You unreasonably prolonged that part of the proceeding that applied to your costs. |
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Our records don't show that you filed your claim for costs within 90 days of our final decision. |
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You didn't state that the issue of costs or the underlying substantive issues are not before or have never been before any
court of the United States with jurisdiction over the issues.
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You didn't give us enough information to decide if you're entitled to claim administrative costs. |
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Other (Explain) |
| You may appeal this decision by filing a petition with the Tax Court for reasonable administrative costs. If this letter is
sent to you by registered or certified mail you must file your petition with the Tax Court before the 91st day after it was
mailed. For more information on how to file a petition, please contact the Clerk of the Tax Court.
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| If you have questions, please contact the person whose name and telephone number are listed above. |
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Sincerely, |
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Signature |
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(Title) |
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Letter 2600 (Rev. 05–99) |
