MEMORANDUM OPINION
GOLDBERG, Special Trial Judge:
This case is before the Court on petitioners' motion for an award of reasonable litigation costs under section 7430. Unless otherwise indicated, all section references are to the Internal Revenue Code of 1986, as amended and in effect for the year in issue. All Rule references are to the Tax Court Rules of Practice and Procedure.
The Internal Revenue Service, Austin, Texas, Service Center (IRS) mailed...
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