Memorandum Opinion
TANNENWALD, Judge:
This case is before the Court on a motion for litigation costs under section 7430 and Rules 230 through 232.
Respondent determined deficiencies in petitioners' Federal income taxes for the taxable years 1983, 1984, 1985, and 1986 in the amounts of $3,660, $25,179, $20,385, and $21,180, respectively, and increased interest
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