Memorandum Opinion
PETERSON, Chief Special Trial Judge:
This matter is before the Court on Petitioner's Motion for an Award of Attorney's Fees and Costs under section 7430 and Rule 231. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
Petitioner's claim for litigation costs arises out of our...
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