Docket No. 20685-94.

72 T.C.M. 384 (1996)

T.C. Memo. 1996-375

Deborah A. Cole v. Commissioner.

United States Tax Court.

Filed August 13, 1996.

Attorney(s) appearing for the Case

Keith H. Cole, Jr., for the petitioner. Stephanie R. Jensen, for the respondent.*


FOLEY, Judge:

This matter is before the Court on petitioner's Motion for Award of Reasonable Administrative and Litigation Costs and Fees under section 7430 and Rule 231.

Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the period relevant here, and all Rule references are to the Tax Court Rules of Practice and Procedure.


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