Ronald A. Horton - Page 11

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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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