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BOUTERIE v. COMMISSIONER

Docket No. 7848-91.

66 T.C.M. 1203 (1993)

T.C. Memo. 1993-510

Rita B. Bouterie v. Commissioner.

United States Tax Court.

Filed November 3, 1993.

Attorney(s) appearing for the Case

Michael A. Mayhall, 700 Camp St., New Orleans, La., for the petitioner. Scott T. Welch, for the respondent.

Memorandum Findings of Fact and Opinion

SHIELDS, Judge:

This matter is before the Court on petitioner's motion for litigation costs under section 74301 and Rule 231. The issues for decision are: (1) Whether respondent's position was substantially justified; and (2) if not, whether the litigation costs claimed by petitioner are reasonable.

Findings of Fact

In a deficiency notice dated January 25, 1991, respondent...

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