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
(continued...)
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