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SPIRTIS v. COMMISSIONER

Docket No. 492-84.

49 T.C.M. 610 (1985)

T.C. Memo. 1985-44

Bernard R. Spirtis and Audrey Spirtis v. Commissioner.

United States Tax Court.

Filed January 28, 1985.

Attorney(s) appearing for the Case

Richard S. Cotler, 2435 Hollywood Blvd., Hollywood, Fla., for the petitioners. David R. Smith, for the respondent.

Memorandum Opinion

DAWSON, Chief Judge:

This case is before the Court on petitioners' Motion for Litigation Costs filed on July 23, 1984, pursuant to Rule 2311 and section 7430.2 The issue for decision is whether respondent's position in the civil proceeding was unreasonable. If this issue is resolved in favor of petitioners, the Court must also decide whether petitioners' litigation costs are reasonable...

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