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BRANTLEY v. COMMISSIONER

Docket No. 10128-94.

70 T.C.M. 1430 (1995)

T.C. Memo. 1995-564

Henry P. and Darlene C. Brantley v. Commissioner.

United States Tax Court.

Filed November 28, 1995.

Attorney(s) appearing for the Case

William J. Irvin and Stephen Gregory Reardon, Richmond, Va., for the petitioners. Scott Anderson, John C. Donovan, and Thomas D. Moffitt, for the respondent.

MEMORANDUM OPINION

JACOBS, Judge:

This matter is before the Court on petitioners' Motion for Litigation and Administrative Costs pursuant to section 7430 and Rule 231. All section references are to the Internal Revenue Code in effect for the matter under consideration, and all Rule references are to the Tax Court Rules of Practice and Procedure.

The substantive issue which gave rise to petitioners' motion involves the 1990 cancellation of a $228...

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