T.C. Memo. 2005-8
UNITED STATES TAX COURT
DENNIS AND NANCY FLYNN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7071-03. Filed January 24, 2005.
Ned Leiba, for petitioners.
Lorraine Y. Wu, for respondent.
MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge: This case is before the Court on
petitioners’ claim for administrative costs under section 7430
and Rule 231.1
1 Unless otherwise specified, section references are to the
Internal Revenue Code as amended, and Rule references are to the
Tax Court Rules of Practice and Procedure.
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