RYAN, Circuit Judge.
After successfully resisting the government's efforts to assess deficiency penalties against them, petitioners sought reasonable litigation costs pursuant to 26 U.S.C. § 7430. The Tax Court denied the petitioners' motions as untimely or, alternatively, for lack of evidence that the respondent acted unreasonably after the petitions were filed. Petitioners appeal. On review we find that the motions were timely. We also conclude that...
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