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WHITESELL v. COMMISSIONER

Docket Nos. 29402-82, 9885-83.

90 T.C. 702 (1988)

VIRGIL M. WHITESELL AND LOIS WHITESELL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed April 18, 1988.

Attorney(s) appearing for the Case

Roger G. Cotner, for the petitioners.

Peter M. Ritteman, for the respondent.

OPINION

TANNENWALD, Judge:

This case is before us on petitioners' motion for reasonable litigation costs under section 74301 and Rule 231. Respondent having conceded that petitioners exhausted their administrative remedies, the issues for decision are (1) whether petitioners were prevailing parties within the meaning of section 7430 and, if so, (2) what litigation expenses are recoverable as reasonable.

Petitioners...

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