MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
This case is before the Court on petitioners' claim for administrative costs under section 7430 and Rule 231.
Petitioners requested that respondent administratively abate the addition to tax under section 6651(a)(2) for failure to pay tax for 1993, 1995, and 1996. Respondent denied their request on January 13, 2000. The parties later settled the case, with respondent...
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