MEMORANDUM OPINION
WHALEN, Judge:
This case is before the Court to decide a motion filed on behalf of the Estate of Daphne Baynham White (hereinafter the estate), entitled "Petitioner's Motion for Costs and Attorney's Fees", in which the estate seeks "litigation costs" in the amount of $3,935. The estate's motion is governed by section 7430 of the Internal Revenue Code (hereinafter all section references are to such Code, unless stated otherwise) and by...
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