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POWERS v. COMMISSIONER

Docket No. 38805-86.

100 T.C. 457 (1993)

MELVIN L. POWERS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 25, 1993.

Attorney(s) appearing for the Case

Robert I. White and Lawrence W. Sherlock, for petitioner.

William G. Bissell and John F. Eiman, for respondent.

COLVIN, Judge:

This case is before the Court on petitioner's motion for award of reasonable litigation costs pursuant to section 7430 and Rule 231.

Respondent determined that petitioner was liable for: (1) Deficiencies of $496,054 for 1978 and $1,288,316 for 1979; (2) additions to tax for negligence under section 6653(a) of $24,803 for 1978 and $64,416 for 1979; and (3) increased interest for tax-motivated transactions under section 6621(d). When the...

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