OPINION
MURRAY M. SCHWARTZ, Senior District Judge.
Plaintiff, James L. Christensen, has moved to recover costs and attorney's fees from the defendant, the United States of America, pursuant to 26 U.S.C. § 7430 (1988) and Rule 54 of the Local Rules of Civil Practice and Procedure of the United States District Court for the District of Delaware (1992). For the reasons which follow, the plaintiff's motion will be granted.
I.
The parties...
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