Maggie Management Company - Page 4

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          Settled Issues.  Respondent filed a response to petitioner's                
          motion for costs on March 3, 1997, pursuant to the Court's Order.           
          No hearing has been requested, and none is necessary.  Rule                 
          232(a)(3).                                                                  
               The issues for decision are whether petitioner qualifies as            
          a "prevailing party" for purposes of section 7430 and, if so,               
          whether the administrative and litigation costs petitioner seeks            
          are reasonable, and whether petitioner has unreasonably                     
          protracted the administrative or court proceedings.                         
                                     Background                                       
               The following facts are based on the entire record,                    
          including the affidavits and exhibits submitted by the parties              
          with respect to the motion for costs, the parties' pleadings,               
          their stipulated settlement, various other motions, and                     
          supporting documents.                                                       
               Petitioner was incorporated in 1984 to assist in managing              
          the business activities and assets of John Ohanesian (Ohanesian)            
          that he had received upon the dissolution of a previous                     
          partnership.  Margaret Gehan (Margaret) is the president, and               
          Glenn M. Gehan (Mike) is the vice president, of petitioner.                 
          Margaret was MMC's sole shareholder during all relevant times.              
               The relationship between petitioner and the Ohanesian family           
          was not defined by written agreements until 1987.  These                    
          agreements provided that petitioner was to provide management or            






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