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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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Last modified: May 25, 2011