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NALLE v. COMMISSIONER

Docket Nos. 22026-89, 22047-89.

67 T.C.M. 2747 (1994)

T.C. Memo. 1994-182

George S. Nalle III and Carole Nalle v. Commissioner. Charles A. Betts and Sylvia I. Betts v. Commissioner.

United States Tax Court.

Filed April 26, 1994.

Attorney(s) appearing for the Case

Michael L. Cook and Carolyn M. Beckett, 600 Congress Ave., Austin, Tex., for the petitioners. Gerald L. Brantley, for the respondent.

Memorandum Opinion

HAMBLEN, Chief Judge:

This matter is before the Court on petitioners' Motion for Award of Litigation Costs filed pursuant to section 7430 and Rule 231.1 We note that the provisions of section 7430 are applicable as amended by section 6239(a) of the Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647, 102 Stat. 3342, 3743, applicable to proceedings commenced after November 10, 1988.

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