T.C. Memo. 2002-237
UNITED STATES TAX COURT
TAM N. HUYNH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13540-99. Filed September 23, 2002.
Bruce E. Gardner, for petitioner.
Roger W. Bracken, for respondent.
MEMORANDUM OPINION
WOLFE, 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. Unless otherwise indicated, all section references
are to the Internal Revenue Code, as amended; however, references
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