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  5. 294 F.Supp.2d 689 (2003)
 

OELSNER v. GOVERNMENT OF VIRGIN ISLANDS OF U.S.

Nos. CIV. 96-0091(STT), CIV. 96-0064(STT).

294 F.Supp.2d 689 (2003)

W. James OELSNER & Carol P. Oelsner, Plaintiffs, v. GOVERNMENT OF THE VIRGIN ISLANDS OF THE UNITED STATES, FOR THE VIRGIN ISLANDS BUREAU OF INTERNAL REVENUE, Defendant.

District Court, Virgin Islands, D. St. Thomas and St. John.

December 3, 2003.

Attorney(s) appearing for the Case

David Bornn, The Bornn Firm PLLC, St. Thomas, VI, for Plaintiffs, W. James Oelsner & Carol Oelsner.

Carol Thomas-Jacobs, Virgin Islands Department of Justice, Civil Division, St. Thomas, VI, for Defendant, The Government of the U.S. Virgin Islands.

OPINION

BROTMAN, District Judge.

This matter is before the Court on a motion by the Plaintiffs, W. James Oelsner and Carol Oelsner (the "Oelsners"), seeking to recover attorney's fees and litigation costs related to their challenge to a tax deficiency determination and a "jeopardy assessment" issued by Virgin Islands Bureau of Internal Revenue (BIR). Under certain circumstances § 7430 of the U.S. Internal Revenue Code, as mirrored in Virgin Islands...

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