MEMORANDUM OPINION
WHALEN, Judge:
This case is before the Court to decide petitioners' motion for an award of reasonable litigation and administrative costs in which they seek attorney's fees and expenses of $5,959.87.
Neither petitioners' motion nor respondent's response thereto requests an evidentiary hearing, and the Court concludes that such a hearing is unnecessary for the disposition of petitioners' motion. See Rule 232(a)(2), Tax Court Rules...
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