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SHARER v. COMMISSIONER

Docket No. 25855-91.

71 T.C.M. 2261 (1996)

T.C. Memo. 1996-90

Mary Lee Sharer v. Commissioner.

United States Tax Court.

Filed February 29, 1996.

Attorney(s) appearing for the Case

Roderick L. MacKenzie and Debra S. Friedman Shoop, Sacramento, Calif., for the petitioner. Kathryn K. Vetter, for the respondent.

MEMORANDUM OPINION

PARR, Judge:

This matter is before the Court on petitioner's motion for an award of administrative and litigation costs under section 74301 and Rule 231. Neither party requested a hearing, and we conclude that a hearing is not necessary to properly dispose of this motion. Rule 232(a)(3).

In our opinion issued on September 8, 1994, Sharer v. Commissioner [Dec. 50,115(M)], T.C...

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