Theron R. Livingston, Sr. - Page 18




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          issues that cannot affect the disposition of the case before                  
          them.”  Id. at 595.                                                           
               Petitioner wife suggests on brief that a decision as to her              
          eligibility for relief under section 6015(b) could enhance her                
          future efforts to petition this Court for an award of attorney’s              
          fees.  It would be inappropriate to protract this proceeding to               
          enhance an award of fees.  See sec. 7430(b)(3).  Moreover, any                
          consideration as to whether petitioner wife is entitled to                    
          litigation and administrative costs, including attorney’s fees,               
          is inappropriate at this stage of these proceedings.  Should                  
          petitioners desire to pursue this matter, they must comply with               
          Rules 230 and 231.                                                            
               Remaining contentions not addressed herein we deem                       
          irrelevant, without merit, or unnecessary to reach.                           
               To reflect the foregoing and concessions by the parties,                 


                                              Decisions will be entered                 
                                         under Rule 155.                                
















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