Charles F. Urbauer - Page 1

                                 T.C. Memo. 1997-546                                  

                               UNITED STATES TAX COURT                                

                          CHARLES F. URBAUER, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5323-95.                 Filed December 11, 1997.           

               Charles F. Urbauer, pro se.                                            
               Mark I. Siegel, for respondent.                                        

                                 MEMORANDUM OPINION                                   
               RAUM, Judge:  The instant matter is before us on                       
          petitioner's motion for reasonable administrative and litigation            
          costs pursuant to section 74301 and Rule 231.  Neither party has            
          requested a hearing on petitioner's motion.  Accordingly, we rule           

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code in effect for the year in issue, and              
          all Rule references are to the Tax Court Rules of Practice and              

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