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COOPER v. COMMISSIONER

Docket No. 13858-97.

77 T.C.M. 1199 (1999)

T.C. Memo. 1999-6

Carolyn B. Cooper v. Commissioner.

United States Tax Court.

Filed January 14, 1999.

Attorney(s) appearing for the Case

Bruce Elwyn Gardner, for the petitioner. Wendy L. Wojewodzki, for the respondent.

MEMORANDUM OPINION

PAJAK, Special Trial Judge:

This case is before the Court pursuant to petitioner's amended motion for award of reasonable litigation costs under section 7430 and Rules 230 through 232. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue. However, all references to section 7430 are to such section as in effect at the time the petition was filed. Ail Rule references are to the...

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