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SCHWARTZ v. COMMISSIONER

Docket No. 13248-00.

88 T.C.M. 167 (2004)

T.C. Memo. 2004-193

Robert Schwartz and Diane Schwartz, v. Commissioner.

United States Tax Court.

August 26, 2004.

Attorney(s) appearing for the Case

Ira B. Stechel, for petitioners;

Peggy J. Gartenbaum, for respondent.

MEMORANDUM OPINION

VASQUEZ, Judge:

This case is before the Court on petitioners' motion for award of reasonable litigation costs pursuant to section 7430 and Rule 231.1 We see no reason for an evidentiary hearing on this matter. See Rule 232(a)(2). Accordingly, we rule on petitioners' motion on the basis of the parties' submissions and the existing record. See Rule 232(a)(1). The portions...

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