Joseph D. Park and Mi Jung Park, et al. - Page 6




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          worth requirement after providing a balance sheet in response to            
          the Commissioner’s opposition).  We will not accept petitioners’            
          unsubstantiated assertions of net worth.  Accordingly, we hold              
          that petitioners are not entitled to an award of litigation                 
          costs.                                                                      
               Contentions we have not addressed are irrelevant, moot, or             
          meritless.                                                                  
               To reflect the foregoing,                                              


                                             An appropriate order will be             
                                        issued denying petitioners’ motion,           
                                        and decisions will be entered under           
                                        Rule 155.                                     

























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