Memorandum Findings of Fact and Opinion
COLVIN, Judge:
This matter is before the Court on petitioners' motion for litigation costs under section 7430 and Rule 231.
After concessions, the issues we must decide are whether respondent's positions relating to: (a) Valuation of property contributed by petitioners to a charitable organization, and (b) petitioners' claim that they substantially complied with section 1.170A-13(b)(3), Income Tax Regs., were...
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