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SOKOL v. COMMISSIONER

Docket No. 18288-84.

92 T.C. 760 (1989)

RONALD M. AND NANCY I. SOKOL, PETITIONERS v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT.

United States Tax Court.

Filed April 5, 1989.

Attorney(s) appearing for the Case

Ronald M. Sokol, pro se.

James E. Cannon, for the respondent.

PARKER, Judge:

This case is before the Court on petitioners' motion for litigation costs under section 7430.1 Specifically, the issue is whether respondent's position in this civil proceeding was unreasonable within the meaning of section 7430(c)(2)(A)(i) [now section 7430(c)(4)(A)(i)].

FINDINGS OF FACT2

At the time the petition was filed, petitioners resided in St. Joseph, Missouri...

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