Memorandum Opinion
NIMS, Chief Judge:
This matter is before the Court on petitioners' motion for award of reasonable litigation 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 as in effect for the years in issue.) The merits of the underlying case were decided in Higgins v. Commissioner [Dec....
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