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EDWIN v. COMMISSIONER

Dkt. No. 7218-06.

94 T.C.M. 300 (2007)

T.C. Memo. 2007-281

Richard Edwin and Eva Ruth Elder v. Commissioner.

United States Tax Court.

September 17, 2007.

Attorney(s) appearing for the Case

Richard E. Elder, pro se.

Margaret A. Martin, for respondent.

MEMORANDUM OPINION

PANUTHOS, Chief Special Trial Judge:

This matter is before the Court on petitioners' motion for an award of administrative and litigation costs pursuant to section 7430 and Rule 231.1 For the reasons discussed below, we shall deny petitioners' motion.

Background

At the time the petition was filed, petitioners resided in Moraga, California. Petitioner Richard Elder is an attorney admitted...

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