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EVANS v. COMMISSIONER

Docket No. 1673-95.

77 T.C.M. 1339 (1999)

T.C. Memo. 1999-33

Joseph W. Evans, Jr. and Mildred S. Evans v. Commissioner.

United States Tax Court.

Filed February 2, 1999.

Attorney(s) appearing for the Case

Joseph W. Evans, Jr. and Mildred S. Evans, pro sese. Howard P. Levine, for the respondent.

MEMORANDUM OPINION

DINAN, Special Trial Judge:

This case is before the Court on petitioners' Motion for An Award of Reasonable Litigation and Administrative Costs pursuant to section 7430 and Rules 230, 231 and 232,1 filed April 11, 1997. Neither party requested a hearing, and we conclude that a hearing is not necessary. Rule 232(a)(3). We decide the matter before us based on the record.

In a statutory notice of deficiency...

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