MEMORANDUM OPINION
FOLEY, Judge:
This matter is before the Court on petitioner's Motion for Award of Reasonable Administrative and Litigation Costs and Fees under section 7430 and Rule 231.
Unless otherwise indicated, all section references are to the Internal Revenue Code as in effect for the period relevant here, and all Rule references are to the Tax Court Rules of Practice and Procedure.
...Let's get started

Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.