T.C. Memo. 2005-106
UNITED STATES TAX COURT
SUSANNE SHAW, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 15888-03. Filed May 11, 2005.
Jeffrey D. Stoermer, for petitioner.
Donald E. Edwards, for respondent.
MEMORANDUM OPINION
GERBER, Chief Judge: This matter is before us on
petitioner’s motion pursuant to Rule 231 for an award of
reasonable administrative and litigation costs under section
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