Memorandum Opinion
COLVIN, Judge:
This matter is before the Court on Petitioners' Motion for Award of Reasonable Litigation Costs under section 7430 and Rule 231.
The case was settled without trial. The basis of settlement was submitted at the calendar call for the case.
The issues for decision are:
(1) Whether we will consider respondent's position before the petition was filed on November 2, 1988, in deciding if respondent's litigation...
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