T.C. Memo. 2005-80
UNITED STATES TAX COURT
PAUL MCGOWAN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13587-01. Filed April 11, 2005.
Daniel L. Britt, Jr., for petitioner.
Travis T. Vance III, for respondent.
MEMORANDUM OPINION
FOLEY, Judge: This matter is before the Court on
petitioner’s motion for recovery of reasonable administrative and
litigation costs pursuant to section 7430 and Rule 231.1 This
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at relevant times, and all
Rule references are to the Tax Court Rules of Practice and
Procedure.
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