Jose A. Salazar - Page 1

                                 T.C. Memo. 2002-157                                  

                               UNITED STATES TAX COURT                                

                           JOSE A. SALAZAR, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 11128-01.                 Filed June 20, 2002.              

               Alfonso Soto, for petitioner.                                          
               Roberta L. Shumway and Kerry H. Bryan, for respondent.                 

                                 MEMORANDUM OPINION                                   

               ARMEN, Special Trial Judge:  Petitioner filed with the Court           
          a petition for administrative costs pursuant to section                     
          7430(f)(2) and Rules 270 through 274.1  In the petition,                    
          petitioner seeks to recover administrative costs in respect of              

               1  Unless otherwise indicated, all section references are to           
          the Internal Revenue Code, as amended, and all Rule references              
          are to the Tax Court Rules of Practice and Procedure.                       

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