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JENSEN v. COMMISSIONER

Docket No. 13005-98.

80 T.C.M. 645 (2000)

T.C. Memo. 2000-341

Ingo H. Jensen v. Commissioner.

United States Tax Court.

Filed November 6, 2000.

Attorney(s) appearing for the Case

Richard F. Battagline and Robert M. Stefancin, for the petitioner. John M. Tkacik, Jr., and Richard S. Bloom, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

POWELL, Special Trial Judge:

This case is before the Court on petitioner's motion for reasonable litigation costs pursuant to section 7430 and Rules 230, 231, and 232,1 filed April 14, 2000.

Neither party requested a hearing, and the Court concludes that a hearing is not necessary for the proper disposition of this motion. Although some facts appear in dispute, those facts are essentially...

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