- 6 - 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.Page: Previous 1 2 3 4 5 6
Last modified: May 25, 2011