MEMORANDUM
MERHIGE, District Judge.
This matter comes before the Court on the motion of plaintiff for an award of attorneys' fees. Plaintiff contends that she is entitled to such an award pursuant to 26 U.S.C. § 7430. Defendants, on the other hand, contend that plaintiff is not entitled to any fees whatever under that section. The motion has been briefed, and the parties have not timely sought oral argument. Accordingly, it is now ripe for disposition...
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