T.C. Memo. 2002-175
UNITED STATES TAX COURT
FREDERICK M. AND CHERYL A. PROUTY, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6020-01. Filed July 24, 2002.
Frederick M. and Cheryl A. Prouty, pro sese.
William W. Kiessling, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
DEAN, Special Trial Judge: This case is before the Court on
petitioners' Motion for Administrative Costs filed pursuant to
section 7430 and Rule 231. All references to section 7430 are to
such section as in effect at the time the petition was filed.
Unless otherwise specified, all other section references are to
the Internal Revenue Code in effect for the year in issue, and
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