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GOON v. COMMISSIONER

Docket No. 16474-05.

92 T.C.M. 354 (2006)

T.C. Memo. 2006-223

Kevin A. Goon v. Commissioner.

United States Tax Court.

October 23, 2006.

Attorney(s) appearing for the Case

Lowell E. Mann, for petitioner.

David A. Breen, for respondent.

MEMORANDUM OPINION

WELLS, Judge:

The instant matter is before the Court on petitioner's motion for reasonable administrative and litigation costs1 pursuant to Rule 2312 and section 7430. The issue we must decide is whether petitioner was the prevailing party. For the reasons stated below, we deny petitioner's motion for reasonable costs.

Background

At the time of filing the...

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