Memorandum Opinion
PETERSON, Chief Special Trial Judge:
This matter is before the Court on petitioners' Motion for Award of Reasonable Litigation and Administrative Costs pursuant to section 7430 and Rule 231, and on respondent's Motion to Dismiss for Lack of Jurisdiction. All section references are to the Internal Revenue Code as amended and in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
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