HARRISON v. COMMISSIONER

Docket No. 29324-91.

69 T.C.M. 1969 (1995)

T.C. Memo. 1995-86

Benjamin J. Harrison v. Commissioner.

United States Tax Court.

Filed March 1, 1995.


Attorney(s) appearing for the Case

Audrey J. Orlando, 2298 Sunrise Dr., San Jose, Calif., for the petitioner. Emily J. Kingston, for the respondent.


Memorandum Opinion

PARR, Judge:

Petitioner has filed a motion for litigation and administrative costs pursuant to section 74301 and Rule 230. The issue for decision is whether the position of respondent in the underlying tax case was substantially justified. We find that it was, and therefore, deny the motion for litigation and administrative costs.

On January 20, 7995,2 petitioner filed a...

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