Memorandum Findings of Fact and Opinion
PARKER, Judge:
Petitioner has filed a Motion for Award of Reasonable Litigation Costs in the amount of $36,870 pursuant to section 7430 and Rule 231. Unless otherwise indicated, all section references are to the Internal Revenue Code as amended and in effect for the relevant years, and all Rule references are to the Tax Court Rules of Practice and Procedure. The Court has concluded that a hearing on the motion is unnecessary...
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