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BRAGG v. COMMISSIONER

Docket No. 18827-90.

102 T.C. 715 (1994)

JACKSON B. BRAGG AND SUZANNE BRAGG, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed May 24, 1994.

Attorney(s) appearing for the Case

B. Gray Gibbs, for petitioners.

Charles A. Baer, for respondent.

OPINION

WRIGHT, Judge:

This matter is before the Court on petitioners' motion for an award of reasonable litigation costs under Rule 231 and section 7430.1 The merits of the underlying case were decided in Bragg v. Commissioner, T.C. Memo. 1993-479, filed October 18, 1993, and to the extent necessary for the disposition of this motion, the facts and holdings in

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