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MADDOX v. COMMISSIONER

Docket No. 20959-96.

76 T.C.M. 1040 (1998)

T.C. Memo. 1998-449

Robert M. and Paulette G. Maddox v. Commissioner.

United States Tax Court.

Filed December 23, 1998.

Attorney(s) appearing for the Case

Daniel W. Schreimann, for the petitioners. James E. Archie, for the respondent.

MEMORANDUM OPINION

CHABOT, Judge:

This matter is before us on petitioners' motion for an award of litigation costs1 pursuant to section 74302 and Rule 231.3

The issue for decision is whether respondent's position in the instant case was substantially justified, within the meaning of section 7430(c)(4)(B)(i).

Neither side has requested a hearing, and we...

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