T.C. Memo. 2001-74
UNITED STATES TAX COURT
JOHN S. GIBSON, f.k.a. JOHN S. MACTAVISH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7628-98. Filed March 23, 2001.
Peter L. Milinkovich, for petitioner.
John C. Schmittdiel, for respondent.
MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge: This case is before
the Court on petitioner’s Motion for Litigation and
Administrative Costs filed pursuant to section 7430 and Rule 231.
All references to section 7430 are to that section as in effect
at the time the petition was filed. Unless otherwise indicated,
all other section references are to the Internal Revenue Code in
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