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LOMANNO v. COMMISSIONER

Docket No. 9275-92.

68 T.C.M. 565 (1994)

T.C. Memo. 1994-426

Regina Lomanno v. Commissioner.

United States Tax Court.

Filed August 24, 1994.

Attorney(s) appearing for the Case

Bruce W. McClain, 24600 Detroit Rd., Westlake, Ohio, for the petitioner. Marc A. Shapiro, for the respondent.

Memorandum Opinion

COUVILLION, Special Trial Judge:

This matter is before the Court on petitioner's motion for an award of attorney's fees and litigation costs pursuant to section 74301 and Rule 231.

In a notice of deficiency addressed to petitioner and her former husband, Frank Lomanno (Mr. Lomanno), respondent determined deficiencies in and additions to their Federal income taxes as follows:

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