- 21 - Respondent's Other Objections to Petitioners' Motion Because the requirements of section 7430 are in the conjunctive, Minahan v. Commissioner, 88 T.C. 492, 497 (1987), our finding that petitioner has failed to prove that respondent's position was not substantially justified, and therefore that petitioner is not a prevailing party, operates in and of itself to deny petitioner's motion. Consequently, we need not address respondent's other objections to the motion. To reflect the foregoing, An appropriate order will be issued denying petitioner's motion, and a decision will be entered herein.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21
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