Locate and read Greg McIntosh, TC Memo 2001-144, 81 TCM 1772, RIA TC Memo 2001-144 (6/19/2001). Answer

Question:

Locate and read Greg McIntosh, TC Memo 2001-144, 81 TCM 1772, RIA TC Memo ¶2001-144 (6/19/2001). Answer the following questions.
a. What requirements must be met for a taxpayer to recover litigation costs from the IRS?
b. Was the taxpayer in this case able to recover his attorney fees from the IRS? Why or why not?