T.C. Memo. 1998-276
UNITED STATES TAX COURT
JOSEPH F. AND CAMILLE T. UDDO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16687-97. Filed July 29, 1998.
William A. Neilson and Joseph John Ecuyer III, for
petitioners.
Linda K. West and Mary Beth Calkins, for respondent.
MEMORANDUM OPINION
POWELL, Special Trial Judge: This case is before the Court
on petitioners' motion for award of reasonable litigation and
administrative costs pursuant to section 7430 and Rules 230, 231,
and 232,1 filed March 24, 1998. Neither party requested a
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect for the year in issue, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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