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controversy or with respect to the most significant issue
presented. See Bragg v. Commissioner, 102 T.C. 715 (1994).
Because petitioners are not the prevailing party, we need
not decide whether petitioners' litigation costs are reasonable,
or whether petitioners unreasonably protracted the court
proceedings. Accordingly, we hold for respondent and
petitioners' motions for litigation costs and to determine
prevailing party will be denied.
To reflect the foregoing,
An appropriate Order and
Decision will be entered
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Last modified: May 25, 2011