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JONDAHL v. COMMISSIONER

Docket No. 13385-02.

92 T.C.M. 9 (2006)

T.C. Memo. 2006-142

James O. Jondahl, v. Commissioner.

United States Tax Court.

July 5, 2006.

Attorney(s) appearing for the Case

Jon J. Jensen, for petitioner.

Inga C. Plucinski, for respondent.

MEMORANDUM OPINION

GOEKE, Judge:

This matter is before the Court on petitioner's Motion Requesting For Reasonable Litigation Costs under section 7430 and Rule 231.1 The issue is whether petitioner is entitled to the costs of litigating his Federal tax liability for the years 1990, 1991, 1992, and 1993 after he conveyed a purported qualified offer in a letter to respondent dated April 27, 2004. We hold that the letter of April...

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