T.C. Memo. 2000-387
UNITED STATES TAX COURT
MICHELE D. LIVINGSTON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15040-97. Filed December 20, 2000.
Howard B. Teller, for petitioner.
Richard A. Stone, for respondent.
MEMORANDUM OPINION
THORNTON, Judge: This case is before the Court on
petitioner’s motion for litigation and administrative costs
pursuant to section 7430 and Rule 231.1
1 References to sec. 7430 in this opinion are to that
section as amended by the Taxpayer Bill of Rights 2, Pub. L. 104-
168, sec. 701, 110 Stat. 1452, 1463 (1996), effective with
respect to proceedings commenced after July 30, 1996. The 1996
(continued...)
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