T.C. Memo. 1998-306
UNITED STATES TAX COURT
GIRISH AND NALINI G. PATEL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 5033-97. Filed August 24, 1998.
Girish and Nalini G. Patel, pro sese.
David B. Mora, for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case is before the
Court on petitioners' motion for an award of reasonable
litigation costs under section 7430. Unless otherwise indicated,
all section references are to the Internal Revenue Code of 1986,
as amended and in effect for the year in issue. All Rule
references are to the Tax Court Rules of Practice and Procedure.
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