Garry F. Bettencourt and Phyllis C. Bettencourt - Page 10




                                       - 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