T.C. Memo. 1996-103
UNITED STATES TAX COURT
D. SHERMAN AND MAXINE M. COX, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 30187-91. Filed March 6, 1996.
John W. Schwartz, Jr., for petitioners.
Anthony Gasaway, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case is before the
Court on petitioners' motion for an award of reasonable
litigation and administrative costs under section 7430.1 The
merits of the underlying case were decided in Cox v.
Commissioner, T.C. Memo. 1993-326, filed July 22, 1993, and to
the extent necessary for the disposition of this motion, the
1 All section references are to the Internal Revenue Code for
the year in issue. All Rule references are to the Tax Court
Rules of Practice and Procedure.
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