- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
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