T.C. Memo. 1999-127
UNITED STATES TAX COURT
MICHAEL H. JOHNSON AND PATRICIA E. JOHNSON, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23702-96. Filed April 16, 1999.
Terry B. Bates, Brian J. Seery, and Robert A. Olson, for
petitioners.
Steven M. Roth, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
petitioners' motion for award of litigation and administrative
costs and attorney's fees pursuant to section 7430 and Rule 231.1
We see no reason for an evidentiary hearing on this matter. See
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, and all Rule references are to the Tax
Court Rules of Practice and Procedure.
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