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DOWNING v. COMMISSIONER

Dkt. No. 12108-98.

89 T.C.M. 1009 (2005)

T.C. Memo. 2005-73

Michael J. Downing and Sandra M. Downing v. Commissioner.

United States Tax Court.

April 6, 2005.

Attorney(s) appearing for the Case

John S. Ponseti, for petitioners;

Susan S. Canavello, for respondent.

SUPPLEMENTAL MEMORANDUM OPINION*

CHABOT, Judge:

This matter is before us on the motion of petitioner Sandra M. Downing1 (hereinafter sometimes referred to as Sandra) for an award of reasonable litigation and administrative costs pursuant to section 74302 and Rule 231.3

The issues for decision are:

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