ORDER
EDWARD C. REED, Jr., District Judge.
This Order addresses an appeal from the Bankruptcy Court Order dated January 6, 1993 granting the debtors' motion to determine the amount of the debtor's claim for litigation costs and awarding $31,237.05 in litigation costs to said debtors. The award of attorneys fees was made pursuant to 26 U.S.C. § 7430 which states in relevant part:
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