MEMORANDUM OPINION
PAJAK, Special Trial Judge:
This matter is before the Court pursuant to petitioners' motions for award of reasonable litigation costs under section 7430 and Rules 230 through 232. Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the years in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
No party has requested a hearing on petitioners' motions...
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