MEMORANDUM OPINION
PARKER, Judge:
This consolidated case is before the Court on petitioners' motion for litigation costs, pursuant to section 7430 and Rules 230 through 232. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the relevant taxable years, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The parties submitted memoranda and affidavits in support of their positions...
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