Estate of Helen G. Williamson, Deceased, Douglas F. Woods, Executor - Page 1

                                 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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