MEMORANDUM OPINION AND ORDER
JOINER, District Judge.
This matter comes before the court on plaintiffs' motion for fees and costs pursuant to 26 U.S.C. § 7430. The parties having fully briefed the issues, the court will rule on this motion without conducting a hearing or oral argument. See Local Rule 17(l)(4).
After conducting a non-jury trial, the court found for plaintiffs in an October 15, 1986, opinion and order, and defendant...
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