T.C. Memo. 2002-247
UNITED STATES TAX COURT
ANTONIO ROSARIO AND JOYCE ROSARIO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1378-00. Filed September 26, 2002.
Robert J. Fedor, for petitioners.
Katherine Lee Kosar, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
petitioners’ motion for award of administrative and litigation
costs pursuant to section 7430 and Rule 231.1 Neither party
1 Unless otherwise indicated, all 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. All references to sec. 7430 are to that section as in
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