- 15 -
377; and Addison Distribution, Inc. v. Commissioner, T.C. Memo.
1998-289. Respondent’s litigating position was substantially
justified under the circumstances.
We hold, therefore, that respondent has established that his
litigating position challenging petitioners’ method of accounting
in Mid-Del I was substantially justified because respondent’s
challenge was reasonable given the facts and circumstances of
petitioners’ cases and the applicable law. Accordingly,
petitioners are not entitled to recover litigation costs. In
light of our ruling, we need not decide whether the costs claimed
by petitioners are reasonable.
We have considered carefully all remaining arguments made by
petitioners for a result contrary to that expressed herein, and,
to the extent not discussed above, we consider them to be
irrelevant or without merit.
To reflect the foregoing,
Appropriate orders and
decisions will be entered.
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