- 51 - Because respondent’s positions in the administrative and court proceedings were substantially justified, we need not decide whether petitioners unreasonably protracted the proceedings, or whether the administrative and litigation costs claimed by petitioners are reasonable. We find that respondent’s positions on the disputed issues were substantially justified. Therefore, we hold that petitioners are not prevailing parties within the meaning of section 7430 and are not entitled to an award of administrative and litigation costs. To reflect the foregoing, An appropriate order and decision will be entered.Page: Previous 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51Last modified: November 10, 2007