T.C. Memo. 2006-135 UNITED STATES TAX COURT SCOTT AND SORAYA MALOWNEY, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19262-03. Filed June 27, 2006. O. Christopher Meyers, for petitioners. William F. Castor, for respondent. MEMORANDUM OPINION FOLEY, Judge: This matter is before the Court on petitioners’ motion for litigation and administrative costs pursuant to section 74301 and Rule 231. The Court held for 1 Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: 1 2 3 4 5 Next
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