OPINION
THORNTON, Judge:
This case is before us on petitioners' motion for reasonable litigation and administrative costs pursuant to section 7430 and Rule 231.
Background
Mr. Grigoraci is a certified public accountant and the chief executive officer (C.E.O.) of an accounting partnership, Grigoraci, Trainer, Wright & Paterno (GTWP). On December 1, 1995, Mr. Grigoraci formed Victor Grigoraci...
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