MEMORANDUM OPINION
SWIFT, Judge:
This matter is before the Court on petitioner's motion for an award of $5,000 in administrative and litigation costs under section 7430.
All section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.
At the time the petition was filed, petitioner resided in Laguna Niguel, California.
In January of 1992, respondent began an audit...
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