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LOCKETT v. COMMISSIONER

Docket No. 1183-93.

67 T.C.M. 2595 (1994)

T.C. Memo. 1994-144

Eldred C. Lockett and Shirley T. Lockett v. Commissioner.

United States Tax Court.

Filed March 31, 1994.

Attorney(s) appearing for the Case

Montie S. Day, 80 Swan Way, Oakland, Calif., for the petitioners. Thomas G. Schleier, for the respondent.

Memorandum Findings of Fact and Opinion

PANUTHOS, Chief Special Trial Judge:

This matter is before the Court on petitioners' motion filed pursuant to Rule 231 for an award of reasonable administrative and litigation costs pursuant to section 7430.1

In their motion, petitioners claim that respondent's position was not substantially justified during the administrative and judicial proceedings concerning petitioners' 1988...

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