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CLINE v. COMMISSIONER

Docket No. 11835-88.

58 T.C.M. 471 (1989)

T.C. Memo. 1989-571

Phillip G. Cline, Sr. v. Commissioner.

United States Tax Court.

Filed October 25, 1989.

Attorney(s) appearing for the Case

Phillip G. Cline, Sr., pro se. Douglas S. Polsky, for the respondent.

Memorandum Findings of Fact and Opinion

PARR, Judge:

This matter is before us on petitioner's motion for award of litigation costs, filed under Rule 2311 and section 7430. Respondent's response in opposition to petitioner's motion raises the following issues for decision: (1) Whether petitioner was the "prevailing party," within the meaning of section 7430(c)(2) (now section 7430(c)(4)); and, if so, (2) whether the amount of...

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