OPINION
SIMANDLE, District Judge.
This matter comes before the Court upon motion by defendant Daniel K. Scheingold for attorneys' fees and costs in the amount of $19,054.90 ($18,952.00 plus $102.90) pursuant to 26 U.S.C. § 7430. For the reasons stated herein, the Court will grant this application because Scheingold substantially prevailed at trial after the government rejected his pre-trial qualified offer of settlement under 26 U.S.C.
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