T.C. Memo. 1996-44
UNITED STATES TAX COURT
DANNY K. ELDRIDGE AND ELMA J. ELDRIDGE, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 28087-92. Filed February 8, 1996.
Richard H. Tye, for petitioners.
Gerald L. Brantley, for respondent.
MEMORANDUM OPINION
PARR, Judge: This matter is before the Court on
petitioners' motion filed September 18, 1995, and supplemental
motion filed November 6, 1995, for litigation costs pursuant to
Rules 230 through 2321 and section 7430.2 In our opinion of
1 All Rule references are to the Tax Court Rules of Practice
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