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ELLISON v. COMMISSIONER

Docket No. 16069-89.

64 T.C.M. 1684 (1992)

T.C. Memo. 1992-741

Cecil W. and Catherine A. Ellison v. Commissioner.

United States Tax Court.

Filed December 30, 1992.

Attorney(s) appearing for the Case

James L. Franklin, 334 Tealwood Dr. Houston, Tex., for the petitioners. William G. Bissell and M. Kathryn Bellis, for the respondent.

Memorandum Findings of Facts and Opinion

DRENNEN, Judge:

This matter is before the Court on petitioners' motion for litigation costs filed on March 6, 1991, pursuant to Rule 2311 and section 7430.

Petitioners Cecil and Catherine Ellison filed joint Federal income tax returns for 1982, 1983, and 1984. By statutory notice of deficiency, dated March 30, 1989, respondent...

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