T.C. Memo. 1999-120
UNITED STATES TAX COURT
JUNG SIK AND BOK S. LIM, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17433-97. Filed April 6, 1999.
Matthew J. McCann, for petitioners.
Wendy L. Wojewodzki, for respondent.
MEMORANDUM OPINION
GERBER, Judge: This matter is before the Court on
petitioners’ motion for award of litigation costs pursuant to
section 74301 and Rule 231.
1 References to sec. 7430 in this opinion are to that
section as amended by the Taxpayer Bill of Rights 2, Pub. L. 104-
168, sec. 701, 110 Stat. 1452, 1463-1464 (1996), effective with
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