- 14 - Based on the foregoing, petitioner has failed to establish that he substantially prevailed with respect to any issue before the Court. Petitioner is therefore not a prevailing party within the meaning of section 7430(c)(4)(A)(i). To reflect the foregoing, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011