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RICHMAN v. COMMISSIONER

Docket No. 17360-91.

67 T.C.M. 2581 (1994)

T.C. Memo. 1994-140

Harry and Rose Richman v. Commissioner.

United States Tax Court.

Filed March 30, 1994.

Attorney(s) appearing for the Case

Jared J. Scharf, 11 Martine Ave., White Plains, N.Y., for the petitioners. William J. Gregg, for the respondent.

Memorandum Opinion

LARO, Judge:

This case is before the Court on the motion of Harry Richman and Rose Richman (petitioners) for reasonable administrative costs, litigation costs, and attorney's fees under section 74301 and Rule 231.2 The issue for decision is whether petitioners have established that they were the "prevailing party" within the meaning of section 7430(c)(4)(A)(i). We conclude that...

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