Gustavo and Veronica Zeron - Page 1

                                 T.C. Memo. 2006-221                                  

                               UNITED STATES TAX COURT                                

                     GUSTAVO AND VERONICA ZERON, Petitioners v.                       
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 16462-05.              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 sought includes both administrative and litigation costs.             

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