BRORBY, Circuit Judge.
Appellants, whom we will refer to as Property Owners, appeal the denial of their application for reasonable litigation costs under § 7430 of the Internal Revenue Code (26 U.S.C. § 7430). The sole issue presented by this appeal is whether the Government's litigation position was substantially justified under § 7430. We hold it was not and remand to the district court to award litigation costs including reasonable attorney fees...
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