Memorandum Opinion
PETERSON, Special Trial Judge:
These consolidated cases are before the Court on petitioners' motion for reasonable litigation costs filed pursuant to Rule 231. (Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure). A petition was filed in this case on May 29, 1990, for the taxable year 1985, and...
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