Memorandum Findings of Fact and Opinion
PARKER, Judge:
Petitioners have filed a Motion for Litigation and Administrative Costs pursuant to section 7430 and Rule 231. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the relevant years, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issue for decision is whether petitioners have established that they were the "prevailing...
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