Richard A. Cloward - Page 1

                                 T.C. Memo. 2006-224                                  

                               UNITED STATES TAX COURT                                

                          RICHARD A. CLOWARD, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16460-05.              Filed October 23, 2006.              

               Lowell E. Mann, for petitioner.                                        
               David A. Breen, for respondent.                                        

                                 MEMORANDUM OPINION                                   

               WELLS, Judge:  The instant matter is before the Court on               
          petitioner’s motion for reasonable administrative and litigation            
          costs1 pursuant to Rule 2312 and section 7430.  The issue we must           

               1Although petitioner titled the instant motion “MOTION FOR             
          AWARD OF REASONABLE ADMINISTRATIVE COSTS”, the attached list of             
          costs includes both administrative and litigation costs.  We                

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