T.C. Memo. 2004-193
UNITED STATES TAX COURT
ROBERT SCHWARTZ AND DIANE SCHWARTZ, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13248-00. Filed August 26, 2004.
Ira B. Stechel, for petitioners.
Peggy J. Gartenbaum, for respondent.
MEMORANDUM OPINION
VASQUEZ, Judge: This case is before the Court on
petitioners’ motion for award of reasonable litigation costs
pursuant to section 7430 and Rule 231.1 We see no reason for an
1 All references to sec. 7430 are to that section of the
Internal Revenue Code as in effect at the time the petition was
filed, and all Rule references are to the Tax Court Rules of
Practice and Procedure.
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