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 taxable
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