MEMORANDUM OPINION
PANUTHOS, Chief Special Trial Judge:
This matter is before the Court on respondent's motion to dismiss for failure to state a claim upon which relief can be granted. The issue for decision is whether petitioners have stated a claim for administrative costs pursuant to section 7430(c)(2). As explained in detail below, we will grant respondent's motion to dismiss for failure to state a claim upon which relief can be granted.
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