T.C. Memo. 1999-6
UNITED STATES TAX COURT
CAROLYN B. COOPER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13858-97. Filed January 14, 1999.
Bruce Elwyn Gardner, for petitioner.
Wendy L. Wojewodzki, for respondent.
MEMORANDUM OPINION
PAJAK, Special Trial Judge: This case is before the Court
pursuant to petitioner's amended motion for award of reasonable
litigation costs under section 7430 and Rules 230 through 232.
Unless otherwise indicated, all section references are to the
Internal Revenue Code in effect for the year in issue. However,
all references to section 7430 are to such section as in effect
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