Gerald Jacoby and Arlene Jacoby - Page 6

            she did not request an Appeals conference after respondent issued                         
            the 30-day letter.                                                                        
                  Petitioner's motion for award of reasonable litigation costs                        
            will be denied.  We need not decide whether respondent's                                  
            litigating position was "not substantially justified" or reach                            
            the further question as to the reasonableness of such costs.                              
                                                      An appropriate order                            
                                                      and decision will be entered.                   


































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