ORDER
FERN M. SMITH, District Judge.
This matter came on for hearing on the plaintiff's application for an award of attorney's fees pursuant to 26 U.S.C. section 7430(a). For the reasons more fully discussed below, the motion is DENIED and this action is DISMISSED.
The complaint for a tax refund was filed by Joo Kim and Ruby Kim (collectively, the Kims) on March 29, 1988. The issues in the case involved the exchange of property, which all parties...
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