Memorandum Opinion
DINAN, Special Trial Judge:
These matters are before the Court on petitioner's motions for attorney's fees and award of costs filed in docket No. 18472-90 on March 19, 1992, and in docket No. 26353-91, on February 21, 1992. These cases will be treated in this opinion as one court proceeding pursuant to section 7430(e).
Respondent mailed a statutory notice of deficiency dated May 31, 1990, to petitioner...
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