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Issue 2. Whether the Administrative and Litigation Costs Sought
by Petitioner Are Reasonable
Since we hold that petitioner cannot recover administrative
costs incurred prior to the issuance of the notice of deficiency,
and that petitioner is not entitled to litigation costs since
respondent was substantially justified in her position with
respect to all of the litigated issues, we need not address the
issue of whether the costs claimed by petitioner are reasonable.
For all of the above reasons, we hold that petitioner is not
entitled to administrative and litigation costs pursuant to
section 7430.
To reflect the foregoing,
An appropriate order
will be issued denying
the motion for litigation
and administrative
costs.
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