MEMORANDUM AND ORDER
CONABOY, District Judge.
Presently before the Court is Plaintiffs' motion for litigation costs filed pursuant to 26 U.S.C. § 7430. The appropriate briefs and memoranda have been filed and the matter is now ripe for our decision.
BACKGROUND
This matter stems from termination assessments made against the Plaintiffs by the Internal Revenue Service for the amount of $54,577.94 each. After the termination assessments...
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