Memorandum Findings of Fact and Opinion
PETERSON, Chief Special Trial Judge.
This matter is before the Court on petitioner's Motion for Litigation Costs pursuant to section 7430 and Rule 231. All section references are to the Internal Revenue Code, as amended and in effect for 1989. All Rule references are to the Tax Court Rules of Practice and Procedure.
Findings of Fact
The petition at issue herein was filed with this Court on June 27...
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