Michael and Tanya Neylan - Page 1

                                 T.C. Memo. 2006-222                                  


                               UNITED STATES TAX COURT                                


                      MICHAEL AND TANYA NEYLAN, Petitioners v.                        
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      


               Docket No. 16443-05.             Filed October 23, 2006.               


               Lowell E. Mann, for petitioners.                                       
               David A. Breen, for respondent.                                        


                                 MEMORANDUM OPINION                                   

               WELLS, Judge:  The instant matter is before the Court on               
          petitioners’ motion for reasonable administrative and litigation            
          costs1 pursuant to Rule 2312 and section 7430.  The issue we must           

               1Although petitioners titled the instant motion “MOTION FOR            
          AWARD OF REASONABLE ADMINISTRATIVE COSTS”, the attached list of             
          costs includes both administrative and litigation costs.  We                
                                                             (continued...)           





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