MEMORANDUM FINDINGS OF FACT AND OPINION
SWIFT, Judge:
Petitioners seek administrative costs under Rule 271 and section 7430(f)(2).
Unless otherwise indicated, all section references are to the Internal Revenue Code in effect at all relevant times, and all Rule references are to the Tax Court Rules of Practice and Procedure.
The issue for decision is whether petitioners are entitled to recover from respondent $7,253 in administrative costs...
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