T.C. Memo. 1997-485
UNITED STATES TAX COURT
GALEDRIGE CONSTRUCTION, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 21463-94. Filed October 28, 1997.
John P. McDonnell, for petitioner.
Ronald G. Dong, for respondent.
MEMORANDUM OPINION
PARR, Judge: This case is before the Court on petitioner's
motion for reasonable litigation costs pursuant to section 74301
1 References to sec. 7430 in this opinion are to that
section as amended by sec. 1551 of the Tax Reform Act of 1986,
Pub. L. 99-514, 100 Stat. 2752 (effective for proceedings
commenced after Dec. 31, 1985), and by sec. 6239(a) of the
Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647,
102 Stat. 3342, 3743-3747 (effective with respect to proceedings
commenced after Nov. 10, 1988). Sec. 7430 was amended most
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