T.C. Memo. 2007-317
UNITED STATES TAX COURT
GABINO DIAZ, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 1853-06. Filed October 23, 2007.
Jeffrey D. Moffatt, for petitioner.
John D. Faucher, for respondent.
MEMORANDUM OPINION
SWIFT, Judge: This matter is before the Court on
petitioner’s motion for an award of litigation costs under
section 7430(a)(2) and Rule 231.
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect at all relevant times, and
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Last modified: November 10, 2007