T.C. Memo. 1999-55
UNITED STATES TAX COURT
DARL N. AND BONNIE S. MILLER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4420-97. Filed February 26, 1999.
David P. Leeper, for petitioners.
Gerald L. Brantley, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: This case is before the Court on
petitioners' motion for award of reasonable litigation costs
pursuant to section 7430 and Rules 230, 231, and 232,1 filed
October 1, 1997. Petitioners did not request a hearing. In his
notice of objection to petitioners' motion for costs, filed by
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the year 1993. All
Rule references are to the Tax Court Rules of Practice and
Procedure.
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