- 10 - Because the provisions of section 7430 are conjunctive, Minahan v. Commissioner, 88 T.C. at 497, and because we hold that respondent's position in these cases was substantially justified, we will deny petitioners' motions. We, therefore, need not address respondent's other objections to the motions. Appropriate orders and decisions will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10
Last modified: May 25, 2011