T.C. Memo. 1999-118
UNITED STATES TAX COURT
PHILLIP LEE ALLEN AND CAROLYN F. ALLEN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 243-97. Filed April 6, 1999.
Jeri Gartside and Joseph Mudd, for petitioners.
Andrew Lee, for respondent.
MEMORANDUM OPINION
GERBER, Judge: Petitioners, by motion under section 7430
and Rule 231,1 seek the award of litigation costs incurred in
this controversy where they have shown that respondent’s
1 Unless otherwise stated, all section references are to
the Internal Revenue Code in effect for the taxable years in
issue, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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