T.C. Memo. 2002-282
UNITED STATES TAX COURT
TAN DANG & KE T. CHAW DANG, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6715-00. Filed November 14, 2002.
Joyce Rebhun, for petitioners.
Michael W. Berwind, for respondent.
MEMORANDUM OPINION
COLVIN, Judge: This matter is before the Court on
petitioners’ motion for litigation costs under section 7430 and
Rule 231. After concessions, the issues for decision are:
1. Whether respondent’s position in the underlying
proceeding was substantially justified. We hold that it was not.
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