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MARIA v. COMMISSIONER

Docket No. 1290-92.

69 T.C.M. 1867 (1995)

T.C. Memo. 1995-64

Cyrus T. Santa Maria and Luisa J. Santa Maria 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 petitioners. Charlotte A. Mitchell, for the respondent.

Memorandum Opinion

PARR, Judge:

Petitioners have 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, petitioners filed a motion for attorney's...

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