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BEELER v. COMMISSIONER

Docket No. 16052-94.

75 T.C.M. 1699 (1998)

T.C. Memo. 1998-44

Larry L. Beeler and Cynthia J. Beeler v. Commissioner.

United States Tax Court.

Filed February 5, 1998.

Attorney(s) appearing for the Case

J. Paul Raymond, Clearwater, Fla., for the petitioners. Judith C. Winkler, for the respondent.

MEMORANDUM OPINION

COLVIN, Judge:

This case is before the Court on petitioners' motion for an award of administrative and litigation costs under section 7430 and Rule 231.

The parties have submitted affidavits and memoranda supporting their positions. We decide the motion based on the memoranda, affidavits, and exhibits attached to the affidavits. The parties do not dispute the material facts in the affidavits or the authenticity of the exhibits...

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