Supplemental Memorandum Opinion
SCOTT, Judge:
This case is before us on petitioners' motion for reasonable litigation costs pursuant to Rules 230 and 231 and section 7430.
Our memorandum findings of fact and opinion in this case was filed June 20, 1990. The taxable years for which deficiencies were determined are the calendar years 1978, 1980, 1981, 1982, and 1983. The years 1978 and 1980 are involved only because of...
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