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GERARD v. COMMISSIONER

Dkt. No. 1032-01.

93 T.C.M. 1259 (2007)

T.C. Memo. 2007-131

Gerard and Audrey Kathleen Hennessey v. Commissioner.

United States Tax Court.

May 24, 2007.

Attorney(s) appearing for the Case

W. Thomas Finley, Tammy S. Wood, and M. Seth Sosolik, for petitioners.

Kathryn F. Patterson, Abbey B. Garber, and Adam L. Flick, for respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

NIMS, Judge:

This matter is before the Court on petitioners' motion for award of reasonable administrative and litigation costs, filed pursuant to section 7430 and Rules 230 through 233, and request for a hearing. Unless otherwise indicated, section references are to sections of the Internal Revenue Code in effect at all relevant times hereunder. References to section 7430 are to the version of that section in effect...

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