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ESTATE OF WALL v. COMMISSIONER

Docket No. 15311-91.

102 T.C. 391 (1994)

ESTATE OF HELEN S. WALL, DECEASED, KATHRYN H. BARTH, PERSONAL REPRESENTATIVE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 7, 1994.

Attorney(s) appearing for the Case

Gordon H. Smith, Jr., for petitioner.

J. Paul Knap, for respondent.

SUPPLEMENTAL OPINION

NIMS, Judge:

The parties have previously been before this Court, and we have issued our opinion on that matter in Estate of Wall v. Commissioner, 101 T.C. 300 (1993). We incorporate our opinion by this reference. Petitioner has timely filed a motion for an award of reasonable administrative and litigation costs pursuant to Rule 231 and section 7430.

All Rule references are to the...

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