Memorandum Findings of Fact and Opinion
JACOBS, Judge.
This matter is before the Court on petitioners' Motion for Legal Fees and Costs under section 7430 and Rule 231. Unless otherwise indicated, 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.
Findings of Fact
Some of the facts have been stipulated and are...
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