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respondent's position on the statute of limitations question, but
we are not prepared to say that respondent was not substantially
justified in urging that position. See Estate of Wall v.
Commissioner, 102 T.C. 391, 394 (1994).
Because we have held that petitioner has not proven that
respondent's position was not substantially justified, we need
not address the other requirements provided in section 7430.
Therefore,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011