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2003 taxable years. Obviously, any services relating to 2002 are
irrelevant in this 2003 tax case. It was petitioner’s job to
sort these out, and this he has not done.
We hold that petitioner is not entitled to an award of costs
and attorney’s fees because respondent’s position was
substantially justified. As a result of our conclusion, we need
not discuss whether petitioner exhausted his administrative
remedies, unreasonably protracted the proceedings, or claimed
unreasonable costs.
We have considered all the contentions and arguments of the
parties not discussed herein, and we conclude they are without
merit, irrelevant, or moot.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011