T.C. Memo. 2000-167
UNITED STATES TAX COURT
DARTMOUTH CLUBS, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13251-98. Filed May 22, 2000.
William F. Patten, for petitioner.
Ronald F. Hood and David N. Brodsky, for respondent.
MEMORANDUM OPINION
PARR, Judge: This case is before the Court on petitioner's
motion for reasonable litigation and administrative costs
pursuant to section 74301 and Rules 230 through 232, filed
1References to sec. 7430 in this opinion are to that section
of the Internal Revenue Code as amended by the Taxpayer Bill of
Rights 2 (TBOR 2), Pub. L. 104-168, secs. 701-704, 110 Stat.
1452, 1463-1464 (1996), which is effective with respect to
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