James Tinnell - Page 1

                                 T.C. Memo. 2001-233                                  

                               UNITED STATES TAX COURT                                

                            JAMES TINNELL, Petitioner v.                              
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 20318-97.                Filed September 6, 2001.           

               W. Leslie Sully, Jr., for petitioner.                                  
               Paul L. Dixon, for respondent.                                         

                                 MEMORANDUM OPINION                                   

               MARVEL, Judge:  This case is before the Court on                       
          petitioner’s motion for award of litigation costs filed pursuant            
          to section 7430 and Rule 231 on June 5, 2001.1  Petitioner seeks            
          to recover litigation costs of $187,958.22 incurred in contesting           

               1Unless otherwise indicated, all section references are to             
          the Internal Revenue Code for the years in issue, and all Rule              
          references are to the Tax Court Rules of Practice and Procedure.            

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