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LIVINGSTON v. COMMISSIONER

Docket No. 15040-97.

80 T.C.M. 908 (2000)

T.C. Memo. 2000-387

Michele D. Livingston v. Commissioner.

United States Tax Court.

Filed December 20, 2000.

Attorney(s) appearing for the Case

Howard B. Teller, for the petitioner. Richard A. Stone, for the respondent.

MEMORANDUM OPINION

THORNTON, Judge:

This case is before the Court on petitioner's motion for litigation and administrative costs pursuant to section 7430 and Rule 231.1

Neither party has requested an evidentiary hearing on petitioner's motion, and we conclude that none is necessary. See Rule 232(a)(1) and (2). We base our decision on the pleadings, petitioner's motion for litigation and administrative costs, respondent...

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