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GRACE FOREIGN EXCHANGE CORPORATION v. COMMISSIONER

Docket No. 1291-92.

69 T.C.M. 1865 (1995)

T.C. Memo. 1995-63

Grace Foreign Exchange Corporation v. Commissioner.

United States Tax Court.

Filed February 6, 1995.

Attorney(s) appearing for the Case

Peter S. Buchanan, 170 Columbus Ave., San Francisco, Calif., for the petitioner. Charlotte A. Mitchell, for the respondent.

Memorandum Opinion

PARR, Judge:

Petitioner has filed a motion for litigation and administrative costs pursuant to section 74301 and Rule 230. The only issue for decision is whether the position of respondent in the underlying tax case was substantially justified. We find that it was, and, therefore, deny the award of litigation and administrative costs.

On January 19, 1995, petitioner filed a motion for attorney's fees...

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