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ESTATE OF WILLIAMSON v. COMMISSIONER

Docket No. 20857-94.

73 T.C.M. 2014 (1997)

T.C. Memo. 1997-77

Estate of Helen G. Williamson, Deceased, Douglas F. Woods, Executor v. Commissioner.

United States Tax Court.

Filed February 12, 1997.

Attorney(s) appearing for the Case

Wendy Abkin, for the petitioner. Elizabeth L. Groenewegen, for the respondent.

MEMORANDUM OPINION

KORNER, Judge:

This case is before the Court on petitioner's motion to recover administrative and litigation costs pursuant to section 7430 and Rule 231.1 The opinion in this case on the substantive issues was issued on September 19, 1996, as T.C. Memo. 1996-426.

Section 7430(a) provides that the prevailing party may be awarded a judgment for (1) reasonable administrative...

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