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HAMPTON v. COMMISSIONER

Docket No. 3092-01.

83 T.C.M. 1861 (2002)

T.C. Memo. 2002-151

Wayne Hampton and Lois Hampton v. Commissioner.

United States Tax Court.

Filed June 13, 2002.

Attorney(s) appearing for the Case

John M. Moles, for the petitioner.

Gary L. Bloom, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

SWIFT, Judge.

Respondent determined a deficiency of $75,075 in petitioners' Federal income tax for 1994.

Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for 1994.

After concessions, the remaining issue for decision is whether petitioners are entitled under section 7430 to an award of $12,339 in litigation costs.

FINDINGS OF FACT

At the...

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