COBURN v. COMMISSIONER

Dkt. No. 6695-04.

91 T.C.M. 1243 (2006)

T.C. Memo. 2006-118

Timothy J. Coburn v. Commissioner.

United States Tax Court.

June 8, 2006.


Attorney(s) appearing for the Case

Richard A. Siegal and Mark S. Gregory, for petitioner.

Michael J. Proto, for respondent.


MEMORANDUM OPINION

WELLS, Judge:

The instant matter is before the Court on petitioner's motion for litigation fees and costs pursuant to section 7430 and Rule 231. The issues to be decided are whether respondent's position in the court proceeding was substantially justified and whether the litigation costs petitioner claims are reasonable. Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to...

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