Caspian Consulting Group, Inc. - Page 1

                                 T.C. Memo. 2006-85                                   


                               UNITED STATES TAX COURT                                


                    CASPIAN CONSULTING GROUP, INC., Petitioner v.                     
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 18124-03.             Filed April 25, 2006.                 


               William E. Taggart, Jr., for petitioner.                               
               Patricia Montero, for respondent.                                      


                                 MEMORANDUM OPINION                                   
               VASQUEZ, Judge:  This case is before the Court on                      
          petitioner’s motion for award of litigation costs and related               
          costs pursuant to section 7430 and Rule 231.1  We see no reason             


               1  All references to sec. 7430 are to that section of the              
          Internal Revenue Code as in effect at the time the petition was             
          filed, and all Rule references are to the Tax Court Rules of                
          Practice and Procedure.                                                     




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