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CAREY v. COMMISSIONER

Docket No. 23735-90.

63 T.C.M. 3134 (1992)

T.C. Memo. 1992-338

Robert M. and Sarah E. Carey v. Commissioner.

United States Tax Court.

Filed June 15, 1992.

Attorney(s) appearing for the Case

Robert M. Carey, pro se. Richard T. Ainsworth, for the respondent.

Memorandum Opinion

PANUTHOS, Chief Special Trial Judge:

This matter is before the Court on petitioner's motion for an award of reasonable administrative and litigation costs pursuant to section 74301 and Rule 231.

In a notice of deficiency dated August 2, 1990, respondent determined a deficiency for the taxable year 1987 in the amount of $1,618. The primary issue placed in...

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