FINDINGS OF FACT AND CONCLUSIONS OF LAW
L. EDWARD FRIEND, II, Bankruptcy Judge.
There are two issues which must be decided. The first is whether the issue of whether to award the debtors attorneys' fees must be decided under the Equal Access to Justice Act (28 U.S.C. § 2412) or the Internal Revenue Code (26 U.S.C. § 7430). The second is whether the Internal Revenue Service shall be held liable for an award of attorneys' fees to the debtors, Henry...
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