MEMORANDUM OPINION
SWIFT, Judge:
This matter is before us on a motion for an award under section 7430 of $1,657.50 in administrative costs, plus costs in connection with the instant motion.
Unless otherwise indicated, all section references are to the Internal Revenue Code, and all Rule references are to the Tax Court Rules of Practice and Procedure.
Background
Graciano V. Espinoza (decedent) died on January 12, 2002, survived...
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