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JOHNSON v. C.I.R.

No. 20-60054.

972 F.3d 655 (2020)

Paul Edwin JOHNSON; Susan H. Johnson, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Fifth Circuit.

FILED August 24, 2020.

Attorney(s) appearing for the Case

Paul Edwin Johnson, Pro Se.

Susan H. Johnson, Pro Se.

Ivan Clay Dale , Bruce Raleigh Ellisen , David A. Hubbert , U.S. Department of Justice, Tax Division, Appellate Section, William M. Paul , Internal Revenue Service, Gilbert Steven Rothenberg, Esq. , Senior Attorney, U.S. Department of Justice, Tax Division, Washington, DC, for Respondent-Appellee.

Before Smith, Willett, and Duncan, Circuit Judges.

Paul and Susan Johnson petitioned the Tax Court for review of an IRS notice of deficiency assessing them about $51,000 in taxes, penalties, and interest. After the dispute was resolved in their favor, the Johnsons moved for costs under 26 U.S.C. § 7430. The Tax Court denied the motion, and we affirm.

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