T.C. Memo. 1998-434
UNITED STATES TAX COURT
ESTATE OF CHARLES K. RUSSELL, DECEASED, LAVADA S. RUSSELL,
EXECUTRIX, AND LAVADA S. RUSSELL, Petitioners v. COMMISSIONER OF
INTERNAL REVENUE, Respondent
Docket No. 6953-97. Filed December 10, 1998.
Farley P. Katz and Charles J. Muller III, for petitioners.
Lewis J. Hubbard, Jr., for respondent.
MEMORANDUM OPINION
GOLDBERG, Special Trial Judge: This case was heard pursuant
to the provisions of section 7443A and Rules 180, 181, and 182.1
This case is before the Court on petitioners’ Motion for
Reasonable Litigation Costs under section 7430. Because of
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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