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DEMETREE v. COMMISSIONER

Dkt. Nos. 20833-96, 20834-96.

94 T.C.M. 126 (2007)

T.C. Memo. 2007-210

David A. Demetree v. Commissioner. David A. Demetree and Deborah Demetree v. Commissioner.

United States Tax Court.

August 1, 2007.

Attorney(s) appearing for the Case

Kenton V. Sands, for petitioners.

Stephen R. Takeuchi, for respondent.

MEMORANDUM OPINION

FOLEY, Judge.

This matter is before the Court on petitioners' motions for award of reasonable litigation and administrative costs pursuant to section 74301 and Rule 231. On November 24, 2003, this Court issued its memorandum opinion in Demetree v. Commissioner [Dec. 55,357(M)], T.C. Memo. 2003-323. We incorporate herein the facts set forth in that opinion.

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