T.C. Summary Opinion 2001-34
UNITED STATES TAX COURT
STEPHEN J. ROLING AND PEGGY A. ROLING, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15224-99S. Filed March 20, 2001.
Stephen J. Roling and Peggy A. Roling, pro sese.
George W. Bezold, for respondent.
DEAN, Special Trial Judge: This case is before the Court on
petitioners' Motion for Litigation and Administrative Costs filed
pursuant to section 7430 and Rule 231. This case was filed
pursuant to the provisions of section 7463 of the Internal
Revenue Code as in effect at the time the petition was filed.
Unless otherwise indicated, all other section references are to
the Internal Revenue Code in effect for the year at issue, and
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