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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