- 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