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section 60151 with respect to certain omitted income and
erroneous deduction items giving rise to deficiencies.
Additionally, we granted petitioner relief from joint and several
liability for various penalties and additions to tax. Petitioner
subsequently moved for an award of litigation costs pursuant to
section 7430 and Rule 231. Neither party requested a hearing on
the matter. Accordingly, we rule on petitioner’s motion for
litigation costs on the basis of the parties’ submissions and the
record in this case.
Background2
For the taxable years 1987 through 1990, petitioner and her
husband, John A. Rowe (Mr. Rowe), filed joint Federal income tax
returns. On June 25, 1993, respondent issued a notice of
deficiency to petitioner and Mr. Rowe for their taxable years
1987, 1988, and 1989. On August 18, 1994, respondent issued a
notice of deficiency to petitioner and Mr. Rowe for their taxable
1References to sec. 6015 are to that section as added to the
Internal Revenue Code by the Internal Revenue Service
Restructuring and Reform Act of 1998, Pub. L. 105-206, sec. 3201,
112 Stat. 734. References to sec. 7430 are to that section as in
effect at the time the petitions were filed. Unless otherwise
indicated, all other section references are to the Internal
Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
2We incorporate herein by this reference our findings of
fact from our Memorandum Opinion in Rowe v. Commissioner, T.C.
Memo. 2001-325 (Rowe I). We provide a brief summary of those
relevant facts and set forth additional facts necessary to decide
this case.
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