FINDINGS OF FACT and CONCLUSIONS OF LAW
SHAPIRO, District Judge.
Before the court is plaintiff's motion for attorneys' fees and costs pursuant to 26 U.S.C.A. § 7430 (West Supp.1986). The court has subject matter jurisdiction pursuant to 28 U.S.C.A. § 1346(a) (West 1976 & Supp.1986).
Plaintiff initially filed this action under 26 U.S.C.A. § 6672 (West 1967 & Supp. 1986), to recover internal revenue taxes, costs, and attorneys...
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