- 17 - position substantially justified. Pierce v. Underwood, 487 U.S. 552 (1988); Powers v. Commissioner, 100 T.C. 457, 472 (1993). 3. Conclusion We conclude that respondent's position was not substantially justified when respondent issued the notice of deficiency or filed the answer. To reflect the foregoing, An order will be issued granting petitioner's motion for an award of litigation costs.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17
Last modified: May 25, 2011