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RATKE v. COMMISSIONER

Docket No. 9641-01L.

129 T.C. 45 (2007)

129 T.C. No. 6

THOMAS J. AND BONNIE F. RATKE, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 5, 2007.

Attorney(s) appearing for the Case

Jack B. Schiffman, for petitioners.

Robert M. Fowler, for respondent.

SUPPLEMENTAL OPINION

CHABOT, Judge:

This matter is before us on petitioners' motion for award of reasonable litigation and administrative costs under section 74301 as well as petitioners' motion for sanctions under section 6673(a)(2) in the instant collection proceeding. The issue for decision is whether two memoranda prepared in connection with the case in chief are protected...

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