T.C. Memo. 1997-77
UNITED STATES TAX COURT
ESTATE OF HELEN G. WILLIAMSON, DECEASED,
DOUGLAS F. WOODS, EXECUTOR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 20857-94. Filed February 12, 1997.
Wendy Abkin, for petitioner.
Elizabeth L. Groenewegen, for respondent.
MEMORANDUM OPINION
K�RNER, Judge: This case is before the Court on
petitioner's motion to recover administrative and litigation
costs pursuant to section 7430 and Rule 231.1 The opinion in
1 All section references are to the Internal Revenue Code
as amended, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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