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ANDREWS v. COMMISSIONER

Docket No. 20930-84.

50 T.C.M. 1404 (1985)

T.C. Memo. 1985-559

Jack G. and M. Georgette Andrews v. Commissioner.

United States Tax Court.

Filed November 13, 1985.

Attorney(s) appearing for the Case

Charles M. Rieders, 1970 Michigan Ave., Cocoa, Fla., for the petitioners. Jane T. Dickinson, for the respondent.

Memorandum Opinion

PETERSON, Special Trial Judge:

This case was assigned to Special Trial Judge Marvin F. Peterson pursuant to section 7456,1 Internal Revenue Code of 1954, as amended. This case is before the Court on petitioners' Motion for an Award of Reasonable Litigation Costs filed on May 21, 1985, pursuant to section 7430 and Rule 231.2 The issues for decision are (1) whether petitioners substantially...

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