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TRZECIAK v. COMMISSIONER OF INTERNAL REVENUE

No. 6370-10.

T.C. Memo. 2012-83

MARC A. TRZECIAK AND MIRIAM TRZECIAK, Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed March 22, 2012.

Attorney(s) appearing for the Case

Vincent J. Nardone and M. Pilar Puerto , for petitioners.

Terry Serena , for respondent.

MEMORANDUM OPINION

CHIECHI, Judge.

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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