Memorandum Opinion
NIMS, Judge:
This matter is before the Court on petitioner's motion for allowance of reasonable litigation costs filed pursuant to section 7430 and Rule 231. (All section references are to 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.) We note that the provisions of section 7430 are applicable as amended by the Technical and Miscellaneous Revenue...
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