T.C. Memo. 1998-44
UNITED STATES TAX COURT
LARRY L. BEELER AND CYNTHIA J. BEELER, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16052-94. Filed February 5, 1998.
J. Paul Raymond, for petitioners.
Judith C. Winkler, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: This case is before the Court on petitioners'
motion for an award of administrative and litigation costs, as
amended and supplemented, under section 7430 and Rule 231.
The parties have submitted affidavits and memoranda
supporting their positions. We decide the motion based on the
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