Memorandum Opinion
PETERSON, Chief Special Trial Judge:
This matter is before the Court on petitioners' Motion for Litigation Costs under section 7430 and Rule 231. (Unless otherwise indicated, all section references are to sections of the Internal Revenue Code as in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.)
On April 15, 1991, this case was called from the trial calendar at St. Paul...
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