Bradley K. Morrison - Page 1

                                 T.C. Memo. 2006-103                                  

                               UNITED STATES TAX COURT                                

                         BRADLEY K. MORRISON, Petitioner v.                           
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 18140-03.              Filed May 15, 2006.                  

               William E. Taggart, Jr., for petitioner.                               
               Patricia Montero, for respondent.                                      

                                 MEMORANDUM OPINION                                   

               VASQUEZ, Judge:  This case is before the Court on                      
          petitioner’s motion for award of litigation costs and related               
          costs pursuant to section 7430 and Rule 231.1  We see no reason             

               1  All references to sec. 7430 are to that section of the              
          Internal Revenue Code as amended and in effect, and all Rule                
          references are to the Tax Court Rules of Practice and Procedure.            

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