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URBAUER v. COMMISSIONER

Docket No. 5323-95.

74 T.C.M. 1354 (1997)

T.C. Memo. 1997-546

Charles F. Urbauer v. Commissioner.

United States Tax Court.

Filed December 11, 1997.

Attorney(s) appearing for the Case

Charles F. Urbauer, pro se. Mark I. Siegel, for the respondent.

MEMORANDUM OPINION

RAUM, Judge:

The instant matter is before us on petitioner's motion for reasonable administrative and litigation costs pursuant to section 74301 and Rule 231. Neither party has requested a hearing on petitioner's motion. Accordingly, we rule on petitioner's motion on the basis of the parties' submissions and the record in the instant case as a whole. We incorporate by reference herein the portions of our opinion...

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