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presented, and (3) the taxpayer met the net worth requirements of
28 U.S.C., sec. 2412(d)(2)(B) (1994), on the date the petition
was filed. Sec. 7430(c)(4)(A). The taxpayer must also show that
all administrative remedies have been exhausted (to obtain a
judgment for litigation costs), section 7430(b)(1), that the
taxpayer has not unreasonably protracted the administrative or
judicial proceedings, section 7430(b)(4), redesignated as (b)(3)
by the 1996 Act, and that the costs claimed are reasonable in
amount, section 7430(c)(1) and (2). These requirements are in
the conjunctive and each must be met in order for the Court to
determine that administrative or litigation costs should be
awarded pursuant to section 7430. Minahan v. Commissioner, 88
T.C. 492 (1987); Renner v. Commissioner, T.C. Memo. 1994-372.
Petitioners contend that they have substantially prevailed
with respect to the amounts in controversy and on the most
significant issue in these cases. They further contend that they
have met the net worth requirements of 28 U.S.C., sec.
2412(d)(2)(B), that they have exhausted the administrative
proceedings available to them within the Internal Revenue
Service, and that they have not unreasonably protracted the
administrative or court proceedings. They also argue that the
costs claimed are reasonable.
Respondent agrees that petitioners have substantially
prevailed, that they meet the net worth requirements of 28
U.S.C., sec. 2412(d)(2)(B), and that they have not unreasonably
protracted the administrative and court proceedings. Respondent
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