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ESTATE OF HUBBERD v. COMMISSIONER

Docket No. 6813-90.

99 T.C. 335 (1992)

ESTATE OF WILLIAM HUBBERD, DECEASED, BLACKSTONE DILWORTH, JR., EXECUTOR, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 16, 1992.

Attorney(s) appearing for the Case

Elwood Cluck and Kevin P. Kennedy, for petitioner.

Lillian Brigman, Steven M. Diamond, and C. Joseph Craven, for respondent.

OPINION

COLVIN, Judge:

This matter is before the Court on petitioner's motion for award of reasonable litigation costs under section 7430 and Rule 231.

Unless otherwise indicated, section references are to the Internal Revenue Code as amended, and Rule references are to the Tax Court Rules of Practice and Procedure.

The issues for decision are:

(1) Whether an estate is a "party" eligible...

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