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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