John C. Bowden and Karol Bowden - Page 1

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                                 T.C. Memo. 1999-30                                   


                               UNITED STATES TAX COURT                                


                      JOHN C. AND KAROL BOWDEN, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 11152-95.               Filed February 1, 1999.             


               David P. Leeper, for petitioners.                                      
               Gerald L. Brantley, for respondent.                                    


                                 MEMORANDUM OPINION                                   

               DEAN, Special Trial Judge: This case was assigned to Special           
          Trial Judge John F. Dean for the purpose of disposing of                    
          petitioners':  (1) Motion for an Award of Reasonable Litigation             
          Costs; and (2) Motion to Determine Prevailing Party Pursuant to