T.C. Memo. 1997-537
UNITED STATES TAX COURT
JOHN E. AND CONCETTA LOZON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 22764-94. Filed December 4, 1997.
V. Jean Owens, for petitioners.
G. Michelle Ferreira, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
petitioners' motion for litigation costs pursuant to section 7430
and Rule 231.1 Neither party requested a hearing on the motion.
1 References to sec. 7430 are to that section as amended by
sec. 1551 of the Tax Reform Act of 1986, Pub. L. 99-514, 100
Stat. 2085, 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, 3743-3746
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