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GANTNER v. COMMISSIONER

Docket No. 2222-86.

92 T.C. 192 (1989)

DAVID E. AND SANDRA L. GANTNER, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed January 30, 1989.

Attorney(s) appearing for the Case

Mark Arth, for the petitioners.

Genelle Forsberg, for the respondent.

OPINION

WELLS, Judge:

This matter is before us on petitioners' motion for litigation costs pursuant to Rule 231 and section 7430.1 On September 29, 1988, we issued our opinion in Gantner v. Commissioner, 91 T.C. 713, in which we held for petitioners on one issue (the applicability of section 1091 to stock options), and for respondent in substantial...

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