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UDDO v. COMMISSIONER

Docket No. 16687-97.

76 T.C.M. 200 (1998)

T.C. Memo. 1998-276

Joseph F. and Camille T. Uddo v. Commissioner.

United States Tax Court.

Filed July 29, 1998.

Attorney(s) appearing for the Case

William A. Neilson and Joseph John Ecuyer III, for the petitioners. Linda K. West and Mary Beth Calkins, for the respondent.

MEMORANDUM OPINION

POWELL, Special Trial Judge:

This case is before the Court on petitioners' motion for award of reasonable litigation and administrative costs pursuant to section 7430 and Rules 230, 231, and 232,1 filed March 24, 1998. Neither party requested a hearing, and the Court concludes that a hearing is not necessary for the proper disposition of this motion.

On their jointly filed 1994 Federal income tax return...

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