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WILLIFORD v. COMMISSIONER

Docket No. 26613-89.

67 T.C.M. 2542 (1994)

T.C. Memo. 1994-135

Graham D. Williford v. Commissioner.

United States Tax Court.

Filed March 30, 1994.

Attorney(s) appearing for the Case

Gary A. Moreland and Arthur R. Snyder, 4006 Beltline Rd., Dallas, Tex., for the petitioner. Martin M. Van Brauman, for the respondent.

Memorandum Opinion

COLVIN, Judge:

This case is before the Court on petitioner's motion for award of reasonable administrative and litigation costs pursuant to section 7430 and Rule 231.1

After concessions, we must decide:

Whether respondent's positions relating to: (a) Valuation of property contributed by petitioner to a charitable organization, and (b) petitioner's treatment of certain paintings as capital assets...

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