Docket Nos. 4255-95, 4354-95.

72 T.C.M. 92 (1996)

T.C. Memo. 1996-317

Simpson Financial Services, Inc. v. Commissioner. Richard H. and Christine R. Simpson. v. Commissioner.

United States Tax Court.

Filed July 15, 1996.

Attorney(s) appearing for the Case

Robert D. Winston, Jr., New Orleans, La., for the petitioners.

Emile L. Hebert III, for the respondent.


LARO, Judge:

Petitioners moved the Court on March 13, 1996, to recover $19,126 of administrative and litigation costs under section 7430 and Rule 231. Petitioners petitioned the Court to redetermine respondent's determination for their 1988 taxable year. On December 20, 1994, respondent had issued petitioners separate notices of deficiency reflecting her determination that they were liable for the following deficiencies in Federal income...

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