Memorandum Findings of Fact and Opinion
FAY, Judge:
Respondent determined a deficiency of $9,649,113.69 in the estate tax due from the Estate of Milton Feldmar. This case is now before us on petitioner's Motion for an Award of Litigation Costs. The issue for decision is whether petitioner is entitled to a recovery of litigation costs pursuant to section 7430.
Findings of Fact
Petitioner is the Estate of Milton...
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