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AVANCENA v. COMMISSIONER

Docket No. 28026-89.

63 T.C.M. 3133 (1992)

T.C. Memo. 1992-337

James and Noreen Avancena v. Commissioner.

United States Tax Court.

Filed June 15, 1992.

Attorney(s) appearing for the Case

Jane Moretz Edmisten, 4400 Jenifer St., N.W., Washington, D.C., for the petitioners. David L. Click, for the respondent.

Memorandum Opinion

CANTREL, Special Trial Judge:

This case was assigned pursuant to the provisions of section 7443A(b)(3) and Rules 180, 181, and 182.1

This matter is before the Court on petitioners' Motion for Attorney's Fees and Litigation Costs (motion for costs) under section 7430 and Rule 231.

By statutory notice of deficiency dated September 7, 1989, respondent determined a deficiency in petitioners' Federal...

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