T.C. Memo. 1996-317 UNITED STATES TAX COURT SIMPSON FINANCIAL SERVICES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent RICHARD H. AND CHRISTINE R. SIMPSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket Nos. 4255-95, 4354-95. Filed July 15, 1996. Robert D. Winston, Jr., for petitioners. Emile L. Hebert III, for respondent. MEMORANDUM OPINION LARO, Judge: Petitioners moved the Court on March 13, 1996, to recover $19,126 of administrative and litigation costs under section 7430 and Rule 231. Petitioners petitioned the Court to redetermine respondent's determination for their 1988 taxablePage: 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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