- 15 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011