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Consequently, petitioners are not a prevailing party as
defined in section 7430(c)(4). As a result of this holding, we
need not address the question of whether petitioner has satisfied
the other requirements of section 7430.2 Petitioners are
not entitled to an award for reasonable administrative and
litigation costs.
To reflect the foregoing,
An order denying
petitioners' motions will be
issued.
2 We note, however, that petitioner's affidavit in support
of costs claimed is woefully inadequate. It simply lists total
amounts paid to various persons, without listing the dates,
number of hours spent, the hourly rate charged, or the specific
work performed by these individuals. Therefore, the request does
not meet the requirements of Rule 231(d).
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Last modified: May 25, 2011