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SHERBO v. COMMISSIONER

Docket No. 16291-98.

78 T.C.M. 742 (1999)

T.C. Memo. 1999-367

Linda Marie Sherbo v. Commissioner.

United States Tax Court.

Filed November 4, 1999.

Attorney(s) appearing for the Case

Douglas A. Drees, for the petitioner. Henry N. Carriger, for the respondent.

MEMORANDUM OPINION

DEAN, Special Trial Judge:

This case is before the Court on petitioner's Motion for Award of Attorney's Fees filed pursuant to section 7430 and Rule 231. All references to section 7430 are to such section as in effect at the time the petition was filed. All other section references are to the Internal Revenue Code in effect for the years in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.

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