Talmadge and Reatha Swanagan - Page 6

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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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