Dudley Joseph and Myrna Dupuy Callahan - Page 23

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          any of the years at issue because they did not pay any taxes in             
          1989, 1990, or 1991.  Amounts withheld during those years were              
          fully refunded to petitioners.  Finally, there are no grounds to            
          award petitioners litigation costs under section 7430, since                
          petitioners are not the prevailing party.                                   
               To reflect the foregoing,                                              

                                             Decision will be entered                 
                                        under Rule 155.                               
                                                                                     






























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