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PORTER v. COMMISSIONER

Docket Nos. 19074-83, 36261-84.

52 T.C.M. 615 (1986)

T.C. Memo. 1986-465

Kenneth Porter v. Commissioner.

United States Tax Court.

Filed September 22, 1986.

Attorney(s) appearing for the Case

William T. Holloran and Barbara T. Kaplan, Rockefeller Plaza, New York, N.Y., for the petitioner. Frances Ferrito Regan, for the respondent.

Memorandum Opinion

NIMS, Judge:

This case is before the Court on petitioner's motion for an award of litigation costs pursuant to Rule 231 and section 7430.1 The issues for decision are: (1) whether petitioner is a "prevailing party" and, if so, (2) whether petitioner has exhausted the administrative remedies available to him within the Internal Revenue Service.

The record...

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