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LEVY v. COMMISSIONER

Docket No. 29170-89.

63 T.C.M. 2927 (1992)

T.C. Memo. 1992-259

Walter J. Levy and Amneris Levy v. Commissioner.

United States Tax Court.

Filed May 6, 1992.

Attorney(s) appearing for the Case

Patricia Tucker, 2400 Louisiana Blvd., N.E., Albuquerque, N.M., and John S. Campbell, 20 First Plaza, Albuquerque, N.M., for the petitioners. Sandra Hayes, for the respondent.

Supplemental Memorandum Opinion

DAWSON, Judge:

This matter is before the Court on petitioners' Motion for Award of Reasonable Litigation Costs under section 7430 and Rule 231. Unless otherwise indicated, all section references herein are to the Internal Revenue Code in effect for the matter under consideration, and all Rule references are to the Tax Court Rules of Practice and Procedure.

In Levy v. Commissioner [Dec. 47,551(M)],

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