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RHOADES, McKEE, AND BOER v. U.S.

No. 1:91:CV:540.

852 F.Supp. 13 (1994)

RHOADES, McKEE, AND BOER, a Michigan partnership; Dale W. Rhoades, Tax Matter Partner; Timothy Hillegonds, Partner; and Rhoades, McKee, Boer, Goodrich and Titta, a Michigan corporation, Plaintiffs, v. UNITED STATES of America, Defendant.

United States District Court, W.D. Michigan.

January 7, 1994.

Attorney(s) appearing for the Case

Dale W. Rhoades, Thomas P. Hogan, Robert C. Shaver, Jr., Rhoades, McKee, Boer, Goodrich, et al., Grand Rapids, MI, for Rhoades, McKee, and Boer, Dale W. Rhoades, and Timothy Hillegonds.

Dale W. Rhoades, Robert J. Dugan, Robert C. Shaver, Jr., Rhoades, McKee, Boer, Goodrich, et al., Grand Rapids, MI, for Rhoades, McKee, Boer, Goodrich and Titta.

Michael L. Schipper, Asst. U.S. Atty., Michael H. Dettmer, U.S. Atty., Grand Rapids, MI, George P. Eliopoulos, U.S. Dept. of Justice, Tax Div., Thomas J. Clark, Dept. of Justice, Washington, DC, for U.S.

OPINION

ENSLEN, District Judge.

The matter before the Court is plaintiffs' motion for reconsideration of this Court's denial of their motion to recover reasonable litigation costs. 846 F.Supp. 565 (1993). Though they do not specify the Rule of Civil Procedure which permits their motion, I presume plaintiffs proceed under Fed.R.Civ.P. 60(b)(1).

Plaintiffs' original motion argued that they were "prevailing...

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