T.C. Memo. 2005-40
UNITED STATES TAX COURT
ROBERT B. KEMP, JR., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket Nos. 5794-98, 143-00. Filed March 3, 2005.
John P. Konvalinka, for petitioner.
Monica D. Armstrong, for respondent.
MEMORANDUM OPINION
FOLEY, Judge: This matter is before the Court on
petitioner’s Motion to Recover Reasonable Litigation Costs
pursuant to section 7430 and Rule 231.1 This Court ruled in
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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