MEMORANDUM FINDINGS OF FACT AND OPINION
LARO, Judge:
Petitioner moves the Court for an award of administrative costs under section 7430(a)(1). We decide whether he is entitled to an award of any of those costs. We hold he is not. Section references are to the applicable versions of the Internal Revenue Code.
FINDINGS OF FACT
Many facts were stipulated. We incorporate herein by this reference the parties' stipulations of fact and the exhibits...
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