MEMORANDUM DECISION & ORDER
McAVOY, Chief Judge.
On November 20, 1992, plaintiff initiated the instant lawsuit seeking a refund of amounts paid to the United States based on an assessment made under 26 U.S.C. § 6672. Since the time of the filing of the complaint, plaintiff has received a full refund of the amounts paid by him. Plaintiff now seeks to recover an award of costs and attorney's fees pursuant to 26 U.S.C. § 7430. Both the plaintiff...
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