Gerald Jacoby and Arlene Jacoby - Page 1

                                       T.C. Memo. 1997-384                                            

                                     UNITED STATES TAX COURT                                          

                      GERALD JACOBY AND ARLENE JACOBY, Petitioners v.                                 
                        COMMISSIONER OF INTERNAL REVENUE, Respondent                                  

                 Docket No. 7073-87.               Filed August 21, 1997.                             

                 Ira B. Stechel and Thomas J. Fleming, Jr., for petitioner                            
           Arlene Jacoby.                                                                             

                 Diane R. Mirabito and Gary W. Bornholdt, for respondent.                             

                                        MEMORANDUM OPINION                                            
                 CLAPP, Judge:  This case is before us on a Motion for Award                          
           of Reasonable Litigation Costs pursuant to section 7430 and Rules                          
           230 through 232 filed by Arlene Jacoby (petitioner).  Gerald                               
           Jacoby (Gerald) is not a party to this motion, and he has reached                          

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