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Petitioner is not a “prevailing party” within the meaning of
section 7430(c)(4)(B), because respondent has established that
his position is substantially justified. Accordingly,
petitioner’s motion for litigation costs is denied.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011