T.C. Memo. 1995-569
UNITED STATES TAX COURT
GABRIEL GUTIERREZ AND CONNIE GUTIERREZ, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 648-93. Filed November 29, 1995.
Gabriel Gutierrez, pro se.
Derek B. Matta, for respondent.
MEMORANDUM OPINION
PARR, Judge: This matter is before the Court on
petitioners' motion filed July 11, 1995, and supplemental motion
filed October 23, 1995, for administrative and litigation costs,
pursuant to section 7430 and Rule 231.1 At the time of filing of
1 All section references are to the Internal Revenue Code,
and all Rule references are to the Tax Court Rules of Practice
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