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GRANT v. COMMISSIONER

Docket No. 22193-93.

70 T.C.M. 340 (1995)

T.C. Memo. 1995-374

David L. and Fagale D. Grant v. Commissioner.

United States Tax Court.

Filed August 8, 1995.

Attorney(s) appearing for the Case

William B. Sellers, Montgomery, Ala., for the petitioners. Horace Crump, for the respondent.

MEMORANDUM OPINION

COUVILLION, Special Trial Judge:

This case is before the Court on petitioners' motion for administrative and litigation costs pursuant to section 74301 and Rule 231. Neither party requested a hearing, and the Court concludes that a hearing is not necessary for the proper disposition of this motion. Rule 232(a)(3).

There are two issues for decision: (1) Whether petitioners have established that the position...

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