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BOTHWELL v. COMMISSIONER

Docket No. 527-93.

69 T.C.M. 2403 (1995)

T.C. Memo. 1995-170

Neville F. Bothwell, Ila D. Bothwell, Susan Bothwell, Paul N. Bothwell, and Joan L. Bothwell v. Commissioner.

United States Tax Court.

Filed April 12, 1995.

Attorney(s) appearing for the Case

Cris John Wenthur, 4180 La Jolla Village Dr., La Jolla, Calif., for the petitioners. Roberta A. Duffy, for the respondent.

Memorandum Opinion

PARKER, Judge:

Petitioners have filed a Motion for Award of Reasonable Administrative and Litigation Costs pursuant to section 7430 and Rule 231. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the relevant years, and all Rule references are to the Tax Court Rules of Practice and Procedure.

The issue for decision is whether petitioners Neville F. Bothwell and Ila D. Bothwell (husband...

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