MEMORANDUM OPINION AND ORDER
NORDBERG, District Judge.
This action is before the court on motion of respondents Robert L. Wenz and Merrick Consultants, Ltd. for costs and attorney's fees pursuant to 28 U.S.C. § 1920, the Equal Access to Justice Act, 28 U.S.C. § 2412, and Rule 37 of the Federal Rules of Civil Procedure. For the reasons set forth below, respondents' petition is denied.
Background
The IRS brought this action...
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