Memorandum Findings of Fact and Opinion
COUVILLION, Special Trial Judge:
This case is before the Court on the motion of petitioner for litigation costs under section 7430
Respondent determined a deficiency of $442 in petitioner's 1985 Federal income tax and additions to tax under section 6653(a)(1) and (a)(2), respectively, of $22 and 50 percent of the interest payable under section 6601 with respect to...
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