SUPPLEMENTAL MEMORANDUM OPINION
SWIFT, Judge:
This matter is before us on petitioner's motion under Rule 231 for an award of $42,376 in litigation costs under section 7430.
Unless otherwise indicated, all 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.
After concessions, the primary issue for decision is whether respondent's...
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