T.C. Memo. 1999-367
UNITED STATES TAX COURT
LINDA MARIE SHERBO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16291-98. Filed November 4, 1999.
Douglas A. Drees, for petitioner.
Henry N. Carriger, for respondent.
MEMORANDUM OPINION
DEAN, Special Trial Judge: This case is before the Court on
petitioner's Motion for Award of Attorney's Fees filed pursuant
to section 7430 and Rule 231. All references to section 7430 are
to such section as in effect at the time the petition was filed.
All other section references are to the Internal Revenue Code in
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