MEMORANDUM OPINION
CLAPP, Judge:
This case is before us on a Motion for Award of Reasonable Litigation Costs pursuant to section 7430 and Rules 230 through 232 filed by Arlene Jacoby (petitioner). Gerald Jacoby (Gerald) is not a party to this motion, and he has reached a settlement with respondent regarding his liabilities for all taxable years.
The findings of fact underlying the substantive dispute between the parties can be found in this Court...
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