T.C. Memo. 2001-41
UNITED STATES TAX COURT
PHUONG K. NGUYEN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16146-99. Filed February 23, 2001.
Bruce E. Gardner, for petitioner.
Warren P. Simonsen and Roger W. Bracken, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the
Court on petitioner’s motion for an award of administrative and
litigation costs, filed pursuant to section 7430 and Rules 230
through 233.1
1 All section references are to the Internal Revenue Code,
as amended; however, references to sec. 7430 are to such section
(continued...)
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