Laura E. Austin - Page 30

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          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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