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PAUL FREHE ENTERS., INC. v. COMMISSIONER

Docket No. 22080-91.

106 T.C. 436 (1996)

PAUL FREHE ENTERPRISES, INC., PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed June 13, 1996.

Attorney(s) appearing for the Case

Jack H. Kaufman, for petitioner.

Linda L. Conway and James J. Posedel, for respondent.

OPINION

CLAPP, Judge:

This case is before us on petitioner's motion for award of reasonable litigation costs pursuant to section 7430 and Rules 230 through 232.

After concessions by respondent, we must decide whether respondent's litigating position was "not substantially justified", as that phrase is used in section 7430(c)(4)(A)(i). If that question is resolved in favor of petitioner, then we must decide whether the amount of costs and attorney...

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