Colvin, Judge: This case is before the Court on petitioner’s motion for award of reasonable litigation costs pursuant to section 7430 and Rule 231. Respondent determined that petitioner was liable for: (1) Deficiencies of $496,054 for 1978 and $1,288,316 for 1979; (2) additions to tax for negligence under section 6653(a) of $24,803 for 1978 and $64,416 for 1979; and (3) incr…
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