T.C. Memo. 2002-110
UNITED STATES TAX COURT
THU CUC THI HUYNH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12535-00. Filed May 1, 2002.
Bruce E. Gardner, for petitioner.
Lindsey D. Stellwagen, for respondent.
MEMORANDUM OPINION
ARMEN, Special Trial Judge: This matter is before the
Court on petitioner’s motion for an award of administrative and
litigation costs, filed pursuant to section 7430 and Rules 230
through 233.1 Petitioner seeks an award of $15,222 in respect of
1 Unless other indicated, all section references are to the
Internal Revenue Code, as amended; however, references to sec.
7430 are to such section in effect at the time that the petition
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