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ALLEMEIER, JR. v. COMMISSIONER

Dkt. No. 19320-03.

91 T.C.M. 758 (2006)

T.C. Memo. 2006-28

Daniel R. Allemeier, Jr. v. Commissioner.

United States Tax Court.

February 16, 2006.

Attorney(s) appearing for the Case

Daniel R. Allemeier, Jr., pro se;

Hans F. Famularo and Loren B. Mark, for respondent.

SUPPLEMENTAL MEMORANDUM OPINION

KROUPA, Judge:

This matter is before the Court on petitioner's motion for litigation fees and costs pursuant to section 7430 and Rule 231.1 The issue is whether petitioner is entitled to recover $16,5222 for expenses incurred in litigating his Federal income tax liability for 2001. We hold that he is not.

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