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.Page: 1 2 3 4 5 6 7 8 9 Next
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