T.C. Memo. 1997-402
UNITED STATES TAX COURT
EUGENE J. PHILLIPS AND BARBARA A. PHILLIPS, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8990-95. Filed September 10, 1997.
Thomas J. Hall and Neil V. Birkhoff, for petitioners.
John C. McDougal, for respondent.
MEMORANDUM OPINION
WELLS, Judge: The instant matter is before us on
petitioners' motion for reasonable litigation costs pursuant to
section 7430 and Rule 231. Unless otherwise noted, all section
references are to the Internal Revenue Code in effect at the
relevant times, and all Rule references are to the Tax Court
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