T.C. Memo. 1996-476
UNITED STATES TAX COURT
LEON L. SICARD AND ELEANOR SICARD, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 11870-93. Filed October 22, 1996.
Jonathan B. Dubitzky and Jesse M. Fried, for petitioners.
David M. Brodsky and Madlyn B. Coyne, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
WELLS, Judge: The instant matter is before us on
petitioners' motion for reasonable administrative and litigation
costs pursuant to section 7430 and Rule 231. Unless otherwise
noted, all section references are to the Internal Revenue Code
(Code) in effect at the relevant times, and all Rule references
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