T.C. Memo. 2006-19
UNITED STATES TAX COURT
IMAGES IN MOTION OF EL PASO, INC., Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 7663-03. Filed February 7, 2006.
David P. Leeper, for petitioner.
Michael K. Park, for respondent.
MEMORANDUM OPINION
GOEKE, Judge: This matter is before the Court on
petitioner’s motion for award of reasonable litigation costs
under section 7430 and Rule 231.1
1Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure.
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