T.C. Memo. 2005-115
UNITED STATES TAX COURT
BARBARA A. OWEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 18856-02. Filed May 19, 2005.
Terri A. Merriam, Wendy S. Pearson, and Jennifer A. Gellner,
for petitioner.
Robert V. Boeshaar and Julie L. Payne, for respondent.
MEMORANDUM OPINION
MARVEL, Judge: This case is before the Court on
petitioner’s motion for reasonable administrative and litigation
costs (motion) pursuant to section 7430 and Rule 231.1
1Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at the time the petition was
filed, and all Rule references are to the Tax Court Rules of
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