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TINNELL v. COMMISSIONER

Docket No. 20318-97.

82 T.C.M. 482 (2001)

T.C. Memo. 2001-233

James Tinnell v. Commissioner.

United States Tax Court.

Filed September 6, 2001.

Attorney(s) appearing for the Case

W. Leslie Sully, Jr., for the petitioner. Paul L. Dixon, for the respondent.

MEMORANDUM OPINION

MARVEL, Judge:

This case is before the Court on petitioner's motion for award of litigation costs filed pursuant to section 7430 and Rule 231 on June 5, 2001.1 Petitioner seeks to recover litigation costs of $187, 958.22 incurred in contesting respondent's deficiency determination for the taxable years 1991 through 1994.

The issues for decision are whether petitioner qualifies as a "prevailing party...

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