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BOYLE v. COMMISSIONER

Docket No. 1838-92.

69 T.C.M. 1910 (1995)

T.C. Memo. 1995-74

Virginia Boyle v. Commissioner.

United States Tax Court.

Filed February 15, 1995.

Attorney(s) appearing for the Case

Leonard S. Roth, 500 Summit Tower, Houston, Tex., for the petitioner. Andrew M. Tiktin, for the respondent.

Memorandum Opinion

FAY, Judge:

This case is before the Court on petitioner's Motion for Litigation Fees and Costs Pursuant to Section 7430(a)(2), filed September 23, 1994. No hearing has been requested; therefore, we shall decide petitioner's motion based on the pleadings, affidavits, and the record in its entirety.

On August 29, 1994, this Court filed its Memorandum Opinion in Boyle v. Commissioner [Dec. 50,096(M)], T.C...

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