- 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.
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Last modified: May 25, 2011