106 T.C. No. 25
UNITED STATES TAX COURT
PAUL FREHE ENTERPRISES, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22080-91. Filed June 13, 1996.
Jack H. Kaufman, for petitioner.
Linda L. Conway and James J. Posedel, for respondent.
Petitioner moved for award of reasonable
litigation costs in a so-called actuarial case.
Held, respondent's position was substantially
justified. Held, further, petitioner's motion for
award of reasonable litigation costs is denied.
OPINION
CLAPP, Judge: This case is before us on petitioner's Motion
for Award of Reasonable Litigation Costs pursuant to section 7430
and Rules 230 through 232.
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