T.C. Memo. 2006-137
UNITED STATES TAX COURT
RAJESH PRABHAKAR, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 23321-04. Filed June 27, 2006.
Rajesh Prabhakar, pro se.
Laura A. McKenna, for respondent.
MEMORANDUM OPINION
FOLEY, Judge: This matter is before the Court on
petitioner’s motion for award of reasonable litigation and
administrative costs pursuant to section 74301 and Rule 231. On
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
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