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BEAVER BOLT, INC. v. COMMISSIONER

Docket No. 22087-93.

73 T.C.M. 1827 (1997)

T.C. Memo. 1997-44

Beaver Bolt, Inc. v. Commissioner.

United States Tax Court.

Filed January 27, 1997.

Attorney(s) appearing for the Case

Merritt S. Yoelin, Portland, Ore., for the petitioners. Cheryl B. Harris, for the respondent.

MEMORANDUM OPINION

COLVIN, Judge:

This matter is before the Court on petitioner's motion for litigation costs under section 74301 and Rule 231. Respondent concedes that petitioner substantially prevailed, exhausted its administrative remedies, and meets the net worth requirements. Sec. 7430(b)(1), (c)(4)(A)(ii)(I), (iii). The remaining issues for decision are:

1. Whether respondent's position in the underlying proceeding...

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