T.C. Memo. 2005-202
UNITED STATES TAX COURT
GARY R. DAVIS, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6343-04. Filed August 24, 2005.
Robert D. Grossman, Jr., for petitioner.
Paul K. Voelker, for respondent.
MEMORANDUM OPINION
LARO, Judge: Petitioner moves the Court under section 7430
to award him litigation costs of $7,893.75.1 Respondent objects
to this motion, arguing: (1) Petitioner did not exhaust his
1 Unless otherwise indicated, section references are to the
applicable versions of the Internal Revenue Code, and Rule
references are to the Tax Court Rules of Practice and Procedure.
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