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TAE M. v. COMMISSIONER

Dkt No. 13586-04.

94 T.C.M. 159 (2007)

T.C. Memo. 2007-223

Tae M. and Young J. Kim v. Commissioner.

United States Tax Court.

August 13, 2007.

Attorney(s) appearing for the Case

Tae M. and Young J. Kim, pro sese.

Michael T. Sargent, for respondent.

MEMORANDUM OPINION

CHIECHI, Judge:

This matter is before the Court on petitioners' motion filed pursuant to Rule 2311 for an award under section 7430 of reasonable litigation costs (petitioners' motion). Neither party has requested a hearing, and we conclude that a hearing is not necessary. Rule 232(a)(2). Based on the submissions of the parties, we shall deny petitioners' motion.

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