John Bowden, Inc. - Page 1

                                 T.C. Memo. 1999-29                                   

                               UNITED STATES TAX COURT                                

                          JOHN BOWDEN, INC., Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11148-95.             Filed February 1, 1999.               

               David P. Leeper, for petitioner.                                       
               Gerald L. Brantley, for respondent.                                    

                                 MEMORANDUM OPINION                                   
               DEAN, Special Trial Judge:  This case was assigned to                  
          Special Trial Judge John F. Dean pursuant to sections 7430, 7443A           
          and Rules 180, 181, and 1821 for the purpose of disposing of                
          petitioner's Motion for Litigation Costs pursuant to Rules 230              

               1All section references, unless otherwise noted, are to the            
          Internal Revenue Code.  All Rule references are to the Tax Court            
          Rules of Practice and Procedure.                                            

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