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PIZZA INDUSTRIES, INC. DOMINO'S PIZZA v. COMMISSIONER

Docket No. 9942-97.

77 T.C.M. 1745 (1999)

T.C. Memo. 1999-108

Pizza Industries, Inc. Domino's Pizza v. Commissioner.

United States Tax Court.

Filed April 2, 1999.

Attorney(s) appearing for the Case

Paul W. Rowe and Kevin M. Bagley, for the petitioner. Gretchen A. Kindel, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge:

This matter is before the Court on petitioner's motion for an award of administrative and litigation costs under section 7430 and Rules 230 through 233.1

After concessions by the parties,2 the sole issue for decision is whether respondent has established that respondent's position was substantially justified in the administrative and court proceedings...

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