T.C. Memo. 2006-222
UNITED STATES TAX COURT
MICHAEL AND TANYA NEYLAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 16443-05. Filed October 23, 2006.
Lowell E. Mann, for petitioners.
David A. Breen, for respondent.
MEMORANDUM OPINION
WELLS, Judge: The instant matter is before the Court on
petitioners’ motion for reasonable administrative and litigation
costs1 pursuant to Rule 2312 and section 7430. The issue we must
1Although petitioners titled the instant motion “MOTION FOR
AWARD OF REASONABLE ADMINISTRATIVE COSTS”, the attached list of
costs includes both administrative and litigation costs. We
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