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HENTZEL v. COMMISSIONER

Docket No. 14220-89.

61 T.C.M. 2941 (1991)

T.C. Memo. 1991-277

Paul & Sara Hentzel v. Commissioner.

United States Tax Court.

Filed June 19, 1991.

Attorney(s) appearing for the Case

Michael Patiky Miller, for the petitioners. Stephen R. Asmussen, for the respondent.

Memorandum Opinion

FAY, Judge:

This matter is before the Court on petitioners' Motion for Award of Reasonable Litigation Costs pursuant to section 74301 and Rule 231, which we treat as a motion for administrative and litigation costs.

Respondent determined a deficiency of $121,142 in petitioners' 1985 Federal income tax, together with additions to tax pursuant to sections...

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