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.Page: 1 2 3 4 5 6 7 8 9 10 11 Next
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