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Accordingly, we hold that petitioners are not entitled to recover
their administrative or litigation costs.
We have considered all of petitioners’ 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.
5(...continued)
receiving the documentation. Consequently, petitioners forced an
administrative proceeding and litigation, instead of a brief
exchange of correspondence.
6This includes both arguments made in petitioners’ motion
and subsequent memorandum of law.
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Last modified: May 25, 2011