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FORMERLY SPRAY RITE SERVICE CORPORATION v. COMMISSIONER

Docket No. 2064-90.

66 T.C.M. 180 (1993)

T.C. Memo. 1993-323

Yapp Corporation, Formerly Spray Rite Service Corporation v. Commissioner.

United States Tax Court.

Filed July 21, 1993.

Attorney(s) appearing for the Case

Cary B. Edgar, 1505 Three First National Plaza, Chicago, Ill., for the petitioner. William T. Derick, for the respondent.

Memorandum Opinion

FAY, Judge.

This matter is before the Court on petitioner's Motion for Award of Reasonable Administrative and Litigation Costs (Motion for Costs) filed pursuant to section 7430 and Rule 231.1 At the outset, we note that the provisions of section 7430 are applicable as amended by the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat. 3342, 3746, effective as to proceedings commenced...

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