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McWILLIAMS v. COMMISSIONER

Docket No. 4651-92.

104 T.C. 320 (1995)

ROBERT LEE McWILLIAMS, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed March 20, 1995.

Attorney(s) appearing for the Case

Stevan Douglas Looney, for petitioner.

T. Richard Sealy III, for respondent.

OPINION

PARR, Judge:

This matter is before the Court on petitioner's motion for litigation and administrative costs filed September 30, 1994, pursuant to Rule 2311 and section 7430. Respondent determined deficiencies in and additions to petitioner's Federal income taxes for tax years 1986, 1987, and 1988. The case has been docketed, tried, and submitted to the Court for decision but has not yet been decided. After trial...

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