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HOGAN v. COMMISSIONER OF INTERNAL REVENUE

No. 14581-06L.

T.C. Memo. 2011-176

MICHAEL J. HOGAN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed July 25, 2011.

Attorney(s) appearing for the Case

Lance A. Gildner , for petitioner.

Terry Serena , for respondent.

MEMORANDUM OPINION

GOEKE, Judge.

This case is before us on petitioner's motion for recovery of reasonable litigation costs under Rule 231,1 to which respondent objects. For the reasons explained herein, we will deny petitioner's motion. We will begin with a full exposition of the history of this case.

Background

Michael J. Hogan was a resident of Ohio when the petition was filed. This is a collection case involving...

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