T.C. Memo. 2000-119
UNITED STATES TAX COURT
EUGENE P. KREMER, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4916-99. Filed April 5, 2000.
Benjamin C. Sanchez and Rebecca A. Walden, for petitioner.
Wendy Abkin, for respondent.
MEMORANDUM OPINION
GERBER, Judge: Petitioner moved for an award of fees and
costs under section 7430.1 Petitioner alleges that he is the
prevailing party, has exhausted administrative remedies, did not
unreasonably protract the administrative or court proceeding, and
1 Section references are to the Internal Revenue Code as
amended and in effect for the period under consideration.
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