Memorandum Findings of Fact and Opinion
PARR, Judge:
This matter is before us on petitioners' motion for litigation costs pursuant to section 7430 and Rule 231. Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended and in effect for all relevant times. All Rule references are to the Tax Court Rules of Practice and Procedure.
Before trial, the parties agreed to a settlement of the disputed deficiencies. On...
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