T.C. Memo. 1999-8
UNITED STATES TAX COURT
GARRY F. BETTENCOURT AND PHYLLIS C. BETTENCOURT, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 7950-96, 17884-96. Filed January 19, 1999.
Donald H. Read, for petitioners.
Daniel J. Parent, for respondent.
MEMORANDUM OPINION
DINAN, Special Trial Judge: These cases are before the
Court on petitioners' motions for litigation and administrative
costs pursuant to section 7430 and Rules 230, 231 and 232,1 filed
1 Unless otherwise indicated, all section references are
to the Internal Revenue Code in effect for the years 1993 and
1994. All Rule references are to the Tax Court Rules of Practice
and Procedure.
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