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substantially justified at all times throughout the proceeding,
it is not necessary for us to address these arguments.4
In keeping with the above,
Appropriate orders and
decisions will be entered.
4 The question of awarding attorney's fees under sec. 7430
where taxpayer's counsel has agreed to provide representation pro
bono seems to be one of first impression. Pro se taxpayers are
not entitled to an award for the value of their services, since
no fee is paid or incurred. Corrigan v. United States, 27 F.3d
436 (9th Cir. 1994); United States v. McPherson, 840 F.2d 244
(4th Cir. 1988); Frisch v. Commissioner, 87 T.C. 838 (1986).
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