Scott and Soraya Malowney - Page 5

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          claimed.”  Rule 231(d); see also Cassuto v. Commissioner, 93 T.C.           
          256, 271 (1989), affd. in part, revd. in part on other grounds              
          and remanded 936 F.2d 736 (2d Cir. 1991).  Petitioners’ affidavit           
          does not describe the specific nature of the work performed by              
          their attorney, the number of hours their attorney worked on each           
          matter, or the date such work was performed.  Accordingly,                  
          petitioners are not entitled to recover administrative and                  
          litigation costs.  Rule 231(d).                                             
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  
               To reflect the foregoing,                                              
                                                 An appropriate order and             
                                            decision will be entered.                 
























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