SUPPLEMENTAL MEMORANDUM OPINION
NIMS, Judge:
This matter is before the Court on petitioner Robert W. Kean III's Motion for Award of Reasonable Litigation Costs, pursuant to section 7430 and Rule 231. Respondent objects. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Petitioner Robert W. Kean III (Mr....
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