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BAYER v. COMMISSIONER

Docket No. 11408-89.

61 T.C.M. 2980 (1991)

T.C. Memo. 1991-282

Nancy J. Johnson Bayer v. Commissioner.

United States Tax Court.

Filed June 24, 1991.

Attorney(s) appearing for the Case

Thomas J. O'Rourke, 815 Connecticut Ave., Washington, D.C., for the petitioner. Diane D. Helfgott, for the respondent.

Memorandum Opinion

DRENNEN, Judge1:

This matter is before the Court on petitioner's motion for litigation costs pursuant to Rule 33(b), or alternatively, section 7430 and Rule 231, which we treat as a motion for administrative and litigation costs. All section references are to the Internal Revenue Code, as amended and in effect during the relevant time periods. Unless otherwise stated, all Rule references are to the Tax Court...

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