CYNTHIA HOLCOMB HALL, Circuit Judge:
Appellants Merritt Yochum and Rose Marie Yochum appeal from the district court's order denying them attorneys' fees and costs pursuant to 26 U.S.C. § 7430. The district court had jurisdiction under 28 U.S.C. § 157(c)(1) and this court has jurisdiction over the Yochums' timely appeal pursuant to 28 U.S.C. § 1291. We affirm.
I.
From 1977 to 1985, Merritt Kent Yochum and Rose Marie Yochum, a married...
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