T.C. Memo. 1999-380
UNITED STATES TAX COURT
REESE B. BELSHEE, JR. AND BETTY J. BELSHEE, Petitioners
v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 2912-99. Filed November 17, 1999.
D. Alden Newland, for petitioners.
William J. Gregg, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This matter is before
the Court on respondent’s motion to dismiss for failure to state
a claim upon which relief can be granted. The issue for decision
is whether petitioners have stated a claim for administrative
costs pursuant to section 7430(c)(2). As explained in detail
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