T.C. Memo. 1996-90
UNITED STATES TAX COURT
MARY LEE SHARER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 25855-91. Filed February 29, 1996.
Roderick L. MacKenzie and Debra S. Friedman Shoop, for
petitioner.
Kathryn K. Vetter, for respondent.
MEMORANDUM OPINION
PARR, Judge: This matter is before the Court on
petitioner's motion for an award of administrative and litigation
costs under section 74301 and Rule 231. Neither party requested
1 All section references are to the Internal Revenue Code
as in effect for the years in issue, and all Rule references are
to the Tax Court Rules of Practice and Procedure, unless
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