Docket No. 11870-93.

72 T.C.M. 1082 (1996)

T.C. Memo. 1996-476

Leon L. Sicard and Eleanor Sicard v. Commissioner.

United States Tax Court.

Filed October 22, 1996.

Attorney(s) appearing for the Case

Jonathan B. Dubitzky and Jesse M. Fried, Boston, Mass., for the petitioners. David M. Brodsky and Madlyn B. Coyne, for the respondent.


WELLS, Judge:

The instant matter is before us on petitioners' motion for reasonable administrative and litigation costs pursuant to section 7430 and Rule 231. Unless otherwise noted, all section references are to the Internal Revenue Code (Code) in effect at the relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. Neither party has requested a hearing on petitioners' motion...

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