MEMORANDUM OPINION
SWIFT, Judge.
This matter is before the Court on petitioner's motion for an award of litigation costs under section 7430(a)(2) and Rule 231.
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Background
At the time the petition was filed, petitioner resided in Newhall...
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