OPINION
NIMS, Judge:
This matter is before the Court on petitions for administrative costs filed pursuant to Rule 271 and section 7430(f)(2). Both sides have filed motions for summary judgment under Rule 121. The issue for consideration is whether petitioners are entitled to reasonable costs for expenses incurred in administrative proceedings with the Internal Revenue Service (IRS) regarding their 1993 gift tax liabilities. Unless otherwise indicated...
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