T.C. Memo. 2006-118
UNITED STATES TAX COURT
TIMOTHY J. COBURN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 6695-04. Filed June 8, 2006.
Richard A. Siegal and Mark S. Gregory, for petitioner.
Michael J. Proto, for respondent.
MEMORANDUM OPINION
WELLS, Judge: The instant matter is before the Court on
petitioner’s motion for litigation fees and costs pursuant to
section 7430 and Rule 231. The issues to be decided are whether
respondent’s position in the court proceeding was substantially
justified and whether the litigation costs petitioner claims are
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