MEMORANDUM OPINION
DEAN, Special Trial Judge:
This matter is before the Court on petitioner's motion for award of reasonable litigation and administrative costs under section 7430
On January 9, 1996, respondent issued to petitioner a statutory notice of deficiency for tax year 1993 determining a deficiency in income tax of $6,166 and a section 6662(a) accuracy-related penalty of $1,233.<...
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