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RAGAN v. C.I.R.

No. 97-60105.

135 F.3d 329 (1998)

Jacqueline RAGAN, Petitioner-Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

February 17, 1998.

Attorney(s) appearing for the Case

Bruce M. Rose, Westchester, IL, Thomas E. Redding, Redding & Associates, Houston, TX, for Petitioner-Appellant.

Joan I Oppenheimer, Gary William Allen, U.S. Dept. of Justice, Tax Div., Appellate Section, Washington, DC, Gilbert S. Rothenberg, U.S. Department of Justice, Tax Division, Washington, DC, Charles Casazza, Clerk, U.S. Tax Court, Washington, DC, Stuart L. Brown, Chief Counsel, Internal Revenue Service, Washington, DC, for Respondent-Appellee.

Before POLITZ, Chief Judge, and HIGGINBOTHAM and DeMOSS, Circuit Judges.

PATRICK E. HIGGINBOTHAM, Circuit Judge:

Jackie Ragan appeals the Tax Court's denial of her petition seeking an income tax refund. Jackie also challenges the Tax Court's rulings on her motions for attorneys' and accountants' fees and for sanctions against the IRS. We AFFIRM the Tax Court's judgment with respect to the refund and sanctions issues, REVERSE the Tax Court's judgment awarding attorneys' and accountants' fees and REMAND for a new calculation of fees.

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