Foothill Ranch Company Partnership, Buck Equities, Ltd., Tax Matters Partner - Page 2

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                    4.  Held, further, the amount sought by P for                     
               litigation costs is not reasonable and is adjusted                     

               Michael S. Harms and McGee Grigsby, for petitioner.                    
               William H. Quealy, Jr. and Paul B. Burns, for respondent.              


               FOLEY, Judge:  This matter is before the Court on                      
          petitioner's motion for an award of litigation costs pursuant to            
          section 7430 and Rule 231.  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 Procedure.                                            
               In early 1987, Laguna Niguel Properties, a Delaware                    
          corporation, purchased the Whiting Ranch, a parcel of                       
          approximately 2,743 acres of undeveloped land.  Laguna                      
          subsequently exchanged the Whiting Ranch for an interest in                 
          Foothill Ranch Company Partnership (FRC), a California limited              
               In March of 1988, FRC and Orange County, California,                   
          executed an agreement that provided: (1) FRC would be allowed to            
          build housing units on the Whiting Ranch; (2) FRC would construct           
          a library, a school, roads, water and sewer lines, and other                

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