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NGUYEN v. COMMISSIONER

Docket No. 16146-99.

81 T.C.M. 1183 (2001)

T.C. Memo. 2001-41

Phuong K. Nguyen v. Commissioner.

United States Tax Court.

Filed February 23, 2001.

Attorney(s) appearing for the Case

Bruce E. Gardner, for the petitioner.

Warren P. Simonsen and Roger W. Bracken, for the respondent.

MEMORANDUM OPINION

ARMEN, Special Trial Judge.

This matter is before the Court on petitioner's motion for an award of administrative and litigation costs, filed pursuant to section 7430 and Rules 230 through 233.1

After concessions by respondent,2 the issues for decision are as follows:

(1) Whether respondent's position in the administrative and court proceedings was substantially...

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