MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge:
This case is before the Court on petitioners' Motion for Award of Administrative and Litigation Costs filed pursuant to section 7430 and Rule 231. All references to section 7430 are to that section as in effect at the time the petition was filed. Unless otherwise stated, all other section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references...
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