T.C. Memo. 2007-281
UNITED STATES TAX COURT
RICHARD EDWIN AND EVA RUTH ELDER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7218-06. Filed September 17, 2007.
Richard E. Elder, for petitioners.
Margaret A. Martin, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on petitioners’ motion for an award of administrative
and litigation costs pursuant to section 7430 and Rule 231.1 For
the reasons discussed below, we shall deny petitioners’ motion.
1 Unless otherwise indicated, section references are to the
Internal Revenue Code in effect at relevant times, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
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Last modified: November 10, 2007