Kevin A. Goon - Page 6

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          of the documentation.  Accordingly, we hold that petitioner is              
          not entitled to recover his administrative or litigation costs.             
               We have considered all of petitioner’s contentions,6 and, to           
          the extent they are not addressed herein, they are irrelevant,              
          moot, or without merit.                                                     
               To reflect the foregoing,                                              

                                        An appropriate order and                      
                                             decision will be entered.                

               6This includes both arguments made in petitioner’s motion              
          and subsequent memorandum of law.                                           

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