T.C. Memo. 2006-258
UNITED STATES TAX COURT
L.S. VINES, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12763-04. Filed November 30, 2006.
David D. Aughtry, for petitioner.
Monica D. Armstrong, for respondent.
MEMORANDUM OPINION
WELLS, Judge: The instant matter is before the Court on
petitioner’s motion for reimbursement of litigation costs,
including attorney’s fees pursuant to section 7430 and Rule 231.
The issues in dispute are: (1) Whether petitioner meets the net
worth requirements of section 7430(c)(4)(A)(ii); (2) whether
petitioner has properly substantiated his claimed litigation
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