Memorandum Opinion
PARR, Judge:
This matter is before the Court on petitioner's motion for litigation costs pursuant to section 7430. All section references are to the Internal Revenue Code, applying section 7430 as in effect when the proceeding was commenced, and all Rule references are to the Tax Court Rules of Practice and Procedure, unless otherwise indicated.
Petitioner resided in Everett, Washington, when the petition was filed in this case...
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