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MICHAEL v. COMMISSIONER

Docket No. 16443-05.

92 T.C.M. 353 (2006)

T.C. Memo. 2006-222

Michael and Tanya Neylan v. Commissioner.

United States Tax Court.

October 23, 2006.

Attorney(s) appearing for the Case

Lowell E. Mann, for petitioners.

David A. Breen, for respondent.

MEMORANDUM OPINION

WELLS, Judge:

The instant matter is before the Court on petitioners' motion for reasonable administrative and litigation costs1 pursuant to Rule 2312 and section 7430. The issue we must decide is whether petitioners were the prevailing party. For the reasons stated below, we deny petitioners' motion for reasonable costs.

Background

At the time of filing...

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