Frederick M. and Cheryl A. Prouty - Page 13

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          protracted the proceedings, or whether the administrative costs             
          claimed by petitioners are reasonable.                                      
               We find that respondent's position on the disputed issue was           
          a reasonable position sufficiently supported by the facts and               
          circumstances in petitioners' case and the existing legal                   
          precedent.  See Pierce v. Underwood, 487 U.S. 552 (1988).                   
          Because we find respondent's position to have been reasonable, we           
          cannot find petitioners to be "prevailing" parties, and their               
          motion will therefore be denied.                                            
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             in accordance with the                   
                                             agreement of the parties.                

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