- 16 -
E. Conclusion
We conclude that respondent's position in the notice of
deficiency had a reasonable basis in both law and fact. Thus, we
hold that respondent's position was substantially justified and
that petitioners are not entitled to an award for administrative
and litigation costs under section 7430. Petitioners' motion for
administrative and litigation costs will be denied.
To reflect the foregoing,
An appropriate order
will be issued denying
petitioners' motion for
an award of administrative
and litigation costs.
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