T.C. Memo. 2006-223
UNITED STATES TAX COURT
KEVIN A. GOON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16474-05. 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
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