T.C. Memo. 1998-65
UNITED STATES TAX COURT
ANITA C. HUMAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 24232-96. Filed February 18, 1998.
Stephen C. Beeler, for petitioner.
Clinton M. Fried, for respondent.
MEMORANDUM OPINION
PARR, Judge: This matter is before the Court on
petitioner's motion for award of litigation and administrative
costs pursuant to section 74301 and Rule 231.
1 References to sec. 7430 in this opinion are to that
section as amended by sec. 1551 of the Tax Reform Act of 1986,
Pub. L. 99-514, 100 Stat. 2085, 2752 (effective for proceedings
(continued...)
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