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COWIE v. COMMISSIONER

No. 1189-06.

93 T.C.M. 1182 (2007)

T.C. Memo. 2007-108

Neil Malcolm Cowie and Karen Christine Shunk v. Commissioner.

United States Tax Court.

May 1, 2007.

Attorney(s) appearing for the Case

Neil Malcolm Cowie and Karen Christine Shunk, pro se.

William J. Gregg, for respondent.

MEMORANDUM OPINION

WELLS, Judge:

The instant matter is before the Court on petitioners' motion for reasonable administrative and litigation costs1 pursuant to Rule 2312 and section 7430. The issues we must decide are whether petitioners were the prevailing party within the meaning of section 7430 and whether petitioners have substantiated any recoverable...

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