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SWANAGAN v. COMMISSIONER

Docket Nos. 10960-99, 10961-99.

80 T.C.M. 392 (2000)

T.C. Memo. 2000-294

Talmadge and Reatha Swanagan v. Commissioner. Talmadge Swanagan v. Commissioner.

United States Tax Court.

Filed September 20, 2000.

Attorney(s) appearing for the Case

Wanda Kamphuis Zatopa, for the petitioners. Jennifer L. Nuding, for the respondent.

MEMORANDUM OPINION

LARO, Judge:

Petitioners move the Court under section 7430 to award them $1,656.25 in attorney's fees and $89.20 in court costs. Respondent objects thereto, arguing: (1) Petitioners did not exhaust their administrative remedies, (2) respondent's position in this proceeding was substantially justified, (3) petitioners generally have not established that they paid the requested costs, and (4) some of the requested costs are unreasonable...

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