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JASIENSKI v. COMMISSIONER

Docket No. 25126-90.

66 T.C.M. 848 (1993)

T.C. Memo. 1993-449

James J. Jasienski and Barbara E. Jasienski v. Commissioner.

United States Tax Court.

Filed September 28, 1993.

Attorney(s) appearing for the Case

Jack A. Weinstein, 805 S. Michigan Ave., Saginaw, Mich., for the petitioners. Timothy S. Murphy, for the respondent.

Memorandum Opinion

COLVIN, Judge:

This matter is before the Court on Petitioners' Motion for Award of Reasonable Litigation and Administrative Costs under section 7430 and Rule 231.1

In the underlying case, Jasienski v. Commissioner, T.C. Memo. 1992-674, we held that petitioners engaged in a limousine service activity for profit under section 183. After concessions, the sole...

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