ROGERS v. COMMISSIONER

Docket No. 16645-85.

53 T.C.M. 1473 (1987)

T.C. Memo. 1987-374

Kenneth A. Rogers and Audrey J. Rogers v. Commissioner.

United States Tax Court.

Filed July 28, 1987.


Attorney(s) appearing for the Case

Steven M. Chamberlain and William E. Whitley, for the petitioners, Willie Fortenberry, for the respondent.


Memorandum Opinion

FEATHERSTON, Judge:

This case is before the Court on petitioners' motion for reasonable litigation costs to which respondent has objected. In accordance with Rule 232,1 the parties have filed affidavits, counter-affidavits, and memoranda in support of their respective positions. The following issues are presented for decision:

1. Whether petitioners exhausted the administrative remedies available to...

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