MEMORANDUM OPINION
WOLFE, Special Trial Judge:
This matter is before the Court on petitioner's motion for an award of administrative costs, filed pursuant to section 7430 and Rules 230 through 233. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Background
Petitioner timely filed her 1998...
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