Memorandum Opinion
SWIFT, Judge:
This case is before the Court on petitioner's motion under section 7430 for an award of administrative and litigation costs.
All section references are to the Internal Revenue Code.
At the time the petition was filed, petitioner resided in San Benito, Texas.
In January of 1989, respondent began an audit of petitioner's Federal income tax returns for 1986, 1987, and 1988. Petitioner did not fully cooperate...
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