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III. Additional Expenses in Pursuing This Motion
In light of our above holdings that petitioner is not
eligible to recover reasonable administrative and litigation
costs under section 7430, we hold that petitioner is not entitled
to recover, as part of her litigation costs, additional expenses
(if any) she incurred in pursuing this motion.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011