Memorandum Opinion
GOLDBERG, Special Trial Judge:
This case was considered pursuant to the provisions of section 7443A(b)(3) of the Internal Revenue Code.
This matter is before the Court on petitioner's motion entitled Demand for Fees and Costs received by this Court on April 1, 1991. We vacated our decision which was entered on March 5, 1991, pursuant to the agreement of the parties, for the purpose of considering petitioner...
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