Memorandum Opinion
NIMS, Chief Judge:
This matter is before the Court on petitioners' Motion for Litigation Costs (motion for costs) filed pursuant to Rule 231. (Unless otherwise indicated, all Rule references are to the Tax Court Rules of Practice and Procedure. All section references are to sections of the Internal Revenue Code in effect during 1976 and 1977.) We vacated our decision entered pursuant to our Opinion in Horn v. Commissioner [Dec....
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