T.C. Memo. 1998-276 UNITED STATES TAX COURT JOSEPH F. AND CAMILLE T. UDDO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 16687-97. Filed July 29, 1998. William A. Neilson and Joseph John Ecuyer III, for petitioners. Linda K. West and Mary Beth Calkins, for respondent. MEMORANDUM OPINION POWELL, Special Trial Judge: This case is before the Court on petitioners' motion for award of reasonable litigation and administrative costs pursuant to section 7430 and Rules 230, 231, and 232,1 filed March 24, 1998. Neither party requested a 1 Unless otherwise indicated, 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.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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