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MEMORANDUM OPINION
HALPERN, Judge: This case is before the Court on
petitioners’ motion for costs (the motion) pursuant to section
7430 and Rules 230 through 233.1 Petitioners seek to recover
costs in the amount of $880 incurred in connection with
respondent’s determination of a deficiency in tax with respect to
their taxable (calendar) year 1998.2 Respondent objects.
Neither party requested an evidentiary hearing, and we conclude
that such a hearing is not necessary for the proper disposition
of the motion. See Rule 232(a)(2). Accordingly, we shall
proceed on the basis of the parties’ submissions. For the
reasons discussed below, we shall deny the motion.
Factual and Procedural Background
Petitioners are husband and wife residing in Camas,
Washington. Petitioners made a joint return of Federal income
tax for 1998 by filing a Form 1040, U.S. Individual Income Tax
Return (1998 return). Petitioners’ certified public accountant
(C.P.A.), David Austen, prepared the 1998 return. On the 1998
return, petitioners claimed deductions (the section 151(c)
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code of 1986, as amended, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
2 Petitioners initially sought to recover costs in the
amount of $1,000. After conferring with respondent pursuant to
Rule 232(c), petitioners reduced the amount of costs for which
they seek recovery to $880.
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