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SIMPSON v. COMMISSIONER

Docket No. 13014-93.

69 T.C.M. 2513 (1995)

T.C. Memo. 1995-194

Robin Simpson v. Commissioner.

United States Tax Court.

Filed May 2, 1995.

Attorney(s) appearing for the Case

W. Patrick Cantrell, 2001 Kirby Dr., Houston, Tex., for the petitioner. Carol Bingham McClure, for the respondent.

Memorandum Opinion

POWELL, Special Trial Judge:

This case is before the Court on petitioner's motion for litigation costs pursuant to section 7430 and Rule 231.1 On September 7, 1994, we vacated our decision entered on August 5, 1994, for the purpose of addressing petitioner's motion, and filed the motion on that date.

The facts underlying this action may be summarized as follows. In May of 1992, revenue agent Gladys...

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