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reject summarily petitioners’ argument that they need not have
met the regulatory requirements of section 301.7430-1(b)(1),
Proced. & Admin. Regs., in order to recover litigation costs
because the 30-day letter was silent as to this requirement. We
have considered all other arguments for a contrary holding and
find those arguments to be irrelevant or without merit. To
reflect the foregoing,
An appropriate order will be
issued, and decisions will be entered in
accordance with the parties’ settlement.
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Last modified: May 25, 2011