T.C. Memo. 2006-142
UNITED STATES TAX COURT
JAMES O. JONDAHL, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 13385-02. Filed July 5, 2006.
Jon J. Jensen, for petitioner.
Inga C. Plucinski, for respondent.
MEMORANDUM OPINION
GOEKE, Judge: This matter is before the Court on
petitioner’s Motion Requesting For Reasonable Litigation Costs
under section 7430 and Rule 231.1 The issue is whether
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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