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DAVIS v. COMMISSIONER

Docket No. 6343-04.

90 T.C.M. 166 (2005)

T.C. Memo. 2005-202

Gary R. Davis v. Commissioner.

United States Tax Court.

August 24, 2005.

Attorney(s) appearing for the Case

Robert D. Grossman, Jr., for petitioner.

Paul K. Voelker, for respondent.

MEMORANDUM OPINION

LARO, Judge.

Petitioner moves the Court under section 7430 to award him litigation costs of $7,893.75.1 Respondent objects to this motion, arguing: (1) Petitioner did not exhaust his administrative remedies, (2) respondent's position in this proceeding was substantially justified, and (3) some of the requested costs are unreasonable. We ordered the parties to stipulate the facts underlying this motion, and...

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