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WORTHAN v. COMMISSIONER OF INTERNAL REVENUE

Docket No. 11003-10.

T.C. Memo. 2012-263

TERRY L. WORTHAN, Petitioner, v. COMMISSIONER OF INTERNAL REVENUE, Respondent.

United States Tax Court.

Filed September 12, 2012.

Attorney(s) appearing for the Case

William T. Holman and David M. Von Hartitzsch , for petitioner.

William F. Castor , for respondent.

MEMORANDUM OPINION

MARVEL, Judge.

Petitioner is seeking an award of reasonable administrative costs pursuant to section 7430(f)(2) and Rule 231.1

Background

The parties submitted this case fully stipulated pursuant to Rule 122. The stipulation of facts is incorporated herein by this reference. Petitioner resided in Oklahoma when he filed his petition.

During the years at issue petitioner was a managing...

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