Sidney and Anna Dishal - Page 1

                                         T.C. Memo. 1999-110                                               

                                       UNITED STATES TAX COURT                                             

                         SIDNEY DISHAL AND ANNA DISHAL, Petitioners v.                                     
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                      

                  Docket No. 687-97.                      Filed April 2, 1999.                             

                  Dan L. Shehi, for petitioners.                                                           
                  Jeremy L. McPherson, for respondent.                                                     

                                          MEMORANDUM OPINION                                               

                  PARR, Judge:  This matter is before the Court on                                         
            petitioners' motion for award of reasonable litigation costs                                   
            pursuant to section 74301 and Rule 231.                                                        

                  1All section references are to the Internal Revenue Code as                              
            amended and in effect, and all Rule references are to the Tax                                  
            Court Rules of Practice and Procedure, unless otherwise                                        

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