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MOODY v. COMMISSIONER

Docket Nos. 2566-88, 1659-89.

70 T.C.M. 678 (1995)

T.C. Memo. 1995-440

Shearn Moody, Jr. v. Commissioner.

United States Tax Court.

Filed September 14, 1995.

Attorney(s) appearing for the Case

William R. Cousins III, for the petitioner. Melanie R. Urban and David E. Whitcomb, for the respondent.

MEMORANDUM OPINION

WRIGHT, Judge:

This matter is before the Court on petitioner's motion for litigation and administrative costs under section 74301 and Rule 231. The merits of the underlying cases were decided in Moody v. Commissioner [Dec. 50,622(M)], T.C. Memo. 1995-195, filed May 2, 1995. To the extent necessary for the disposition of this motion, the facts and holdings in

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