MEMORANDUM OPINION
PAJAK, Special Trial Judge:
This case is before the Court pursuant to petitioner's motion for litigation and administrative costs under section 7430 and Rules 230 through 233. Unless otherwise indicated, all section references are to the Internal Revenue Code. All Rule references are to the Tax Court Rules of Practice and Procedure.
Petitioner's motion was filed on May 7, 1998. Petitioner claimed the following administrative and...
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