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SCOTT v. COMMISSIONER

Dkt. No. 19262-03.

91 T.C.M. 1305 (2006)

T.C. Memo. 2006-135

Scott and Soraya Malowney v. Commissioner.

United States Tax Court.

June 27, 2006.

Attorney(s) appearing for the Case

O. Christopher Meyers, for petitioners;

William F. Castor, for respondent.

MEMORANDUM OPINION

FOLEY, Judge:

This matter is before the Court on petitioners' motion for litigation and administrative costs pursuant to section 74301 and Rule 231. The Court held for petitioners in a bench opinion dated January 11, 2005. We incorporate herein the facts set forth in that opinion.

Background

In 1996, Soraya Malowney decided to start a business involving the rehabilitation and sale of...

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