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establish that: (1) The position of the United States in the
proceeding was not substantially justified; (2) the claimant
prevailed with respect to the amount in controversy or with
respect to the most significant issue presented; and (3) the
claimant met the net worth requirements of 28 U.S.C. sec.
2412(d)(2)(B) on the date the petition was filed. In addition
to the above, the claimant must also establish that all
administrative remedies have been exhausted insofar as litigation
costs are concerned; that the claimant has not unreasonably
protracted the proceedings; and that the amount of costs claimed
is reasonable. Sec. 7430(b)(1), (4). The moving party bears the
burden of proof with respect to each of the above-listed
elements. Rule 232(e).
Respondent objects to petitioners' motions on several
grounds. First, she argues that her position was substantially
justified. Secondly, she argues that petitioners have
unreasonably protracted the proceedings. Thirdly, she argues
that Abraham has failed to satisfy the net worth requirements.
Fourthly, she argues that a fee arrangement between counsel and
petitioners precludes any award under section 7430. Lastly,
respondent argues that the amounts of costs and attorney's fees
that petitioners are seeking are not reasonable.
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