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McGOWAN v. COMMISSIONER

Dkt. No. 13587-01.

89 T.C.M. 1044 (2005)

T.C. Memo. 2005-80

Paul McGowan v. Commissioner.

United States Tax Court.

April 11, 2005.

Attorney(s) appearing for the Case

Daniel L. Britt, Jr., for petitioner.

Travis T. Vance III, for respondent.

MEMORANDUM OPINION

FOLEY, Judge:

This matter is before the Court on petitioner's motion for recovery of reasonable administrative and litigation costs pursuant to section 7430 and Rule 231.1 This Court ruled in favor of petitioner in McGowan v. Commissioner [Dec. 55,669(M)], T.C. Memo. 2004-146, and we incorporate herein the facts set forth in that opinion.

Background

In 1998, petitioner was convicted...

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