T.C. Memo. 1995-534
UNITED STATES TAX COURT
BOCA CONSTRUCTION, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18570-92. Filed November 13, 1995.
Richard S. Lynch and John Kennedy Lynch, for petitioners.
Mario J. Fazio and J. Scott Broome, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: This matter is before the Court on
petitioner's motion for award of administrative and litigation
costs under section 7430 and Rule 231.
To prevail, petitioner must show that respondent's position
in the underlying administrative and judicial proceeding was not
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