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LEEWAYE v. COMMISSIONER

Docket No. 23335-87.

55 T.C.M. 485 (1988)

T.C. Memo. 1988-129

Rudy G. Leewaye and Helen M. Leewaye v. Commissioner.

United States Tax Court.

Filed March 28, 1988.

Attorney(s) appearing for the Case

Alan R. Herson, 28061 Front St., Temecula, Calif., for the petitioners. Alice M. Harbutte, for the respondent.

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 Award of Litigation Costs filed on November 5, 1987, pursuant to section 7430 and Rule 231(a)(2).2 The issues for decision are (1) whether respondent's position in the...

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