Memorandum Findings of Fact and Opinion
WHALEN, Judge:
This case is before the Court to decide petitioners' motion for litigation costs. The sole issue is whether petitioners are entitled to an award of litigation costs, pursuant to section 7430 of the Internal Revenue Code. All section references made herein are to the Internal Revenue Code, as amended.
Findings of Fact
Our findings of fact are based on petitioners' motion, respondent...
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