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ESTATE OF RUSSELL v. COMMISSIONER

Docket No. 6953-97.

76 T.C.M. 978 (1998)

T.C. Memo. 1998-434

Estate of Charles K. Russell, Deceased, Lavada S. Russell, Executrix, and Lavada S. Russell v. Commissioner.

United States Tax Court.

Filed December 10, 1998.

Attorney(s) appearing for the Case

Farley P. Katz and Charles J. Muller III, for the petitioners. Lewis J. Hubbard, Jr., for the respondent.

MEMORANDUM OPINION

GOLDBERG, Special Trial Judge:

This case was heard pursuant to the provisions of section 7443A and Rules 180, 181, and 182.1

This case is before the Court on petitioners' Motion for Reasonable Litigation Costs under section 7430. Because of concessions by respondent, the sole issue now before us is the allowable amount of recovery by petitioners for litigation costs under section 7430.

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