David E. Heasley and Kathleen Heasley, Cross-Appellees v. Commissioner of Internal Revenue, Cross-Appellant

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• holding that the burden is on the prevailing party to establish number of attorney hours expended, and that such hours were reasonable
• holding that petitioner had failed to show that government's position on valuation penalty was not substantially justified because legal issue \was in flux” and the \IRS simply argued for one of two plausible interpretations of the statute”
• taxpayers challenged the reasonableness of the Commissioner's position with respect to four separate penalties; award of costs proportionate to number of issues on which taxpayers prevailed in that endeavor

Source: CourtListener parenthetical corpus (CC0).