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DARTMOUTH CLUBS, INC. v. COMMISSIONER

Docket No. 13251-98.

79 T.C.M. 2060 (2000)

T.C. Memo. 2000-167

Dartmouth Clubs, Inc. v. Commissioner.

United States Tax Court.

Filed May 22, 2000.

Attorney(s) appearing for the Case

William F. Patten, for the petitioner. Ronald F. Hood and David N. Brodsky, for the respondent.

MEMORANDUM OPINION

PARR, Judge:

This case is before the Court on petitioner's motion for reasonable litigation and administrative costs pursuant to section 74301 and Rules 230 through 232, filed February 2, 2000.

The issues for decision are: (1) Whether petitioner is the prevailing party in the underlying tax case, within the meaning of section 7430(c)(4). We hold it...

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