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WASIE v. COMMISSIONER

Docket No. 27913-84.

86 T.C. 962 (1986)

MARIE F. WASIE, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 12, 1986.

Attorney(s) appearing for the Case

Patrick F. Flaherty, for the petitioner.

Jack Forsberg, for the respondent.

OPINION

GERBER, Judge:

This case is before the Court solely upon petitioner's motion for litigation costs pursuant to section 7430.1 The issues for consideration are (1) whether respondent's position in the civil proceeding was unreasonable, and (2) whether pre-litigation conduct of respondent should be considered in determining reasonableness and, if so, whether pre- and/or post-litigation costs should be awarded.

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