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PHILLIPS v. COMMISSIONER

Docket No. 8990-95.

74 T.C.M. 505 (1997)

T.C. Memo. 1997-402

Eugene J. Phillips and Barbara A. Phillips v. Commissioner.

United States Tax Court.

Filed September 10, 1997.

Attorney(s) appearing for the Case

Thomas J. Hall, Roanoke, Va., and Neil V. Birkhoff, for the petitioners. John C. McDougal, for the respondent.

MEMORANDUM OPINION

WELLS, Judge:

The instant matter is before us on petitioners' motion for reasonable litigation costs pursuant to section 7430 and Rule 231. Unless otherwise noted, all section references are to the Internal Revenue Code in effect at the relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure. Neither party has requested a hearing on petitioners' motion. Accordingly, we rule on petitioners' motion on...

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