Nadeem Chowdhury and Brenda S. Garth Chowdhury - Page 2

                            T.C. Summary Opinion 2001-26                              

                               UNITED STATES TAX COURT                                

           NADEEM CHOWDHURY AND BRENDA S. GARTH CHOWDHURY, Petitioners v.             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11683-99S.                   Filed March 9, 2001.           

               Nadeem Chowdhury and Brenda Chowdhury, pro sese.                       
               Gerald L. Brantley and Silvia M. Rheinbolt, for respondent.            

               PAJAK, Special Trial Judge: This case was heard pursuant to            
          section 7463.  Unless otherwise indicated, all section references           
          are to the Internal Revenue Code in effect for the year in issue,           
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
               This case is before the Court pursuant to petitioners'                 
          motion for litigation costs under section 7430 and Rules 230                
          through 233.  Petitioner claimed $3,920 of litigation costs based           

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