United States Tax Court.
MEMORANDUM OPINION
CHIECHI,
This matter is before us on petitioners' motion that petitioners entitled "MOTION FOR AWARD OF REASONABLE LITIGATION AND ADMINISTRATIVE COSTS" and that we have recharacterized as petitioners' motion for an award under section 7430 of reasonable litigation costs (petitioners' motion). We shall deny petitioners' motion.
Background
The record establishes and/or the parties do not dispute...
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