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ARENDT v. COMMISSIONER

Docket No. 30182-91.

69 T.C.M. 1802 (1995)

T.C. Memo. 1995-53

Robert A. Arendt v. Commissioner.

United States Tax Court.

Filed January 31, 1995.

Attorney(s) appearing for the Case

Jon R. Vaught, for the petitioner. Thomas M. Rohall, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

Petitioner has filed a motion for litigation and administrative costs pursuant to section 74301 and Rule 230. There are two issues for decision: (1) Whether petitioner has established that the position of respondent in the underlying tax case was not substantially justified; and (2) whether special skills were required by petitioner's counsel to warrant an award of attorney...

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