United States Ninth Circuit

Knudsen v. Commissioner of Internal Revenue, 13-72077

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In a case involving a settlement made to the IRS for non-payment of personal income taxes, the Tax Court's decision denying attorney's fees and costs is reversed where a unilateral concession by the Internal Revenue Service (IRS) is not a settlement, for purposes of the Qualified Offer Rule (QOR) of the Internal Revenue Code, 26 U.S.C. section 7430(c)(4)(E).

Appellate Information

Decided 07/15/2015
Published 07/15/2015

Judges

Walter

Court