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COFFEY v. COMMISSIONER

Docket No. 15942-86.

55 T.C.M. 226 (1988)

T.C. Memo. 1988-78

Donald R. Coffey and Janis I. Coffey v. Commissioner.

United States Tax Court.

Filed February 24, 1988.

Memorandum Opinion

PETERSON, Special Trial Judge:

This case was assigned to Special Trial Judge Marvin F. Peterson pursuant to the provisions of section 7443A(b) of the Code.1 This case is before the Court on petitioners' Motion For Litigation Costs filed on January 8, 1987, pursuant to section 7430 and Rule 231.2 The issues for decision are (1) whether respondent's position in the civil proceeding...

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