-30-
cannot be recovered in a suit against the Government in the
absence of an express waiver of a sovereign immunity from an
award of interest." Library of Congress v. Shaw, 478 U.S. 310,
311 (1986). There is absolutely no language in section
7430(c)(1) that indicates Congress intended to waive the
Government's immunity from interest awards. Miller v. Alamo, 992
F.2d 766 (8th. Cir. 1993). Accordingly, we deny petitioner's
request for interest on the award of costs.
Accordingly, we award petitioner attorney's fees in the
amount of $10,602, miscellaneous litigation costs of $611,
accountant and expert witness fees of $3,288, and
research/paralegal fees of $1,000.
Appropriate orders and decisions
will be entered.
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