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SHIFMAN v. COMMISSONER

Docket No. 21632-86.

53 T.C.M. 1337 (1987)

T.C. Memo. 1987-347

Sylvia Shifman v. Commissoner.

United States Tax Court.

Filed July 20, 1987.

Attorney(s) appearing for the Case

Nancy Bateman, for the petitioner. Patricia Delzotti, for the respondent.

Memorandum Findings of Fact and Opinion

POWELL, Special Trial Judge:1

The underlying substantive tax issues in this case were conceded by respondent. The case is before this Court on petitioner's motion for litigation costs pursuant to section 7430 and Rule 231.2

The issues for decison are (1) whether petitioner is a "prevailing party" and, if so, (2) whether petitioner has exhausted her administrative...

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