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FLA. COUNTRY CLUBS, INC. v. COMMISSIONER

Docket No. 9160-02.

122 T.C. 73 (2004)

122 T.C. No. 3

FLORIDA COUNTRY CLUBS, INC., A FLORIDA CORPORATION, SUNCOAST COUNTRY CLUBS, INC., A FLORIDA CORPORATION, DEBORAH A. HAMILTON, AND JAMES R. MIKES, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed February 3, 2004.

Attorney(s) appearing for the Case

James R. Mikes, for petitioners.

Michael D. Zima, for respondent.

OPINION

KROUPA, Judge:

This matter is before the Court on respondent's motion for summary judgment under Rule 121.1 The sole issue for decision is whether petitioners are entitled to reasonable administrative costs under section 7430 for expenses incurred in proceedings within the Internal Revenue Service (IRS) regarding their 1993 and 1994 Federal income taxes. For the reasons explained below, we find that petitioners...

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