- 14 -
We hold that respondent's positions had a reasonable basis
in law and fact. Accordingly, petitioner is not entitled to
administrative and litigation costs under section 7430.
To reflect the foregoing,
An appropriate order will be
issued denying petitioner's
motion for an award of
administrative and litigation
costs, and a 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