NOONAN, Circuit Judge:
Rudolph L. Bertolino sought attorneys fees from the government under Internal Revenue Code § 7430. The Tax Court denied the request. We affirm the Tax Court.
FACTS
Bertolino filed his federal income tax return for 1985, in which he claimed a net operating loss carryover of $38,102.42 and long term capital gain deductions. The return reported taxable income of $6,243.22 and income tax due of $482 which was offset by a general...
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