Memorandum Opinion
SWIFT, Judge:
This case is before the Court on petitioners' motion filed pursuant to Rule 231 for an award of administrative and litigation costs under section 7430.
Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure, and all section references are to the Internal Revenue Code.
On February 13, 1992, the parties filed with the Court a stipulation of settled issues in which...
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