Memorandum Opinion
CHABOT, Judge:
This matter is before us on petitioners' motion for litigation costs, under section 7430 and Rule 231.
Respondent determined deficiencies in Federal corporate income tax, deficiencies in Federal individual income tax, and additions to tax under sections 6653(a) (negligence, etc.) and 6653(b) (fraud), as in effect for the years in issue, against the respective petitioners for the years...
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