- 8 -
pay any of the litigation costs at issue. See Swanson v. Commis-
sioner, 106 T.C. 76, 101-102 (1996).5 We further find that no
litigation costs may be awarded under section 7430.
To reflect the foregoing,
An appropriate order denying
PFI's motion will be issued.
5 Indeed, Partnership was not even in existence on the date the
petition in this case was filed.
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