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.
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