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TAMMARO v. COMMISSIONER

Docket No. 22972-97.

80 T.C.M. 173 (2000)

T.C. Memo. 2000-243

Robert L. and Joanne Tammaro v. Commissioner.

United States Tax Court.

Filed August 7, 2000.

Attorney(s) appearing for the Case

Robert L. Tammaro, pro se. Michael D. Baker, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge:

This matter is before the Court on the motion filed by petitioner Robert L. Tammaro (petitioner)1 for an award of administrative and litigation costs under section 7430 and Rules 230 through 233.2

After concessions by respondent,3 the issues for decision are as follows:

(1) Whether respondent's position in...

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