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REINHARDT v. COMMISSIONER

Docket No. 12321-92.

69 T.C.M. 1954 (1995)

T.C. Memo. 1995-82

Virgil E. and Lorraine Reinhardt v. Commissioner.

United States Tax Court.

Filed February 23, 1995.

Attorney(s) appearing for the Case

Raymond N. McCabe, 70 Niagara St., Buffalo, N.Y., and Edward M. Griffith, Jr., 50 Fountain Plaza, Buffalo, N.Y., for the petitioners. Matthew I. Root, for the respondent.

Memorandum Opinion

COLVIN, Judge:

This matter is before the Court on petitioners' motion for litigation costs under section 7430 and Rule 231.

Respondent determined that petitioners are liable for deficiencies in Federal income tax of $3,487 for 1986, $5,498 for 1987, $6,677 for 1988, and $6,281 for 1989. Respondent also determined that petitioners are liable for additions to tax for fraud for 1986, 1987, 1988, and 1989. Respondent alternatively...

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