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FULLER v. COMMISSIONER

Docket No. 5722-85.

51 T.C.M. 336 (1986)

T.C. Memo. 1986-33

Kenneth L. and Mildred V. Fuller v. Commissioner.

United States Tax Court.

Filed January 27, 1986.

Attorney(s) appearing for the Case

William L. Raby, for the petitioners. Roger Rhodes, for the respondent.

Memorandum Opinion

CANTREL, Special Trial Judge:

We have before us for consideration and ruling thereon a Motion for Award of Reasonable Litigation Costs, filed by counsel for petitioners' on December 31, 1985.1 The Court will decide that motion herein. See Rule 50(b)(3).2

It has long been settled that a valid petition may not be filed in the Tax Court without the issuance of a valid statutory...

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