- 10 - buyer and seller in Watson attributed substantial value to the unmatured crop. Id. at 550. Watson is not analogous to this case because here the parties to the exchange attributed no value to sand which had not been mined or otherwise separated from the realty. We conclude that respondent's position in the notice of deficiency that petitioners transferred assets other than land had no basis in law. D. Conclusion We conclude that respondent's position had no basis in fact or law and was not substantially justified. Thus, petitioners are entitled to an award for administrative and litigation costs under section 7430. To reflect the foregoing, An appropriate order will be issued granting petitioners' motion for an award of administrative and litigation costs, as amended and supplemented.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011