OPINION AND ORDER
NORGLE, District Judge:
Before the court is the plaintiffs' application for attorneys' fees and costs. For the following reasons, the application is denied.
DISCUSSION
The income taxes of plaintiffs Ralph J. Solone and Virginia Solone (the "Solones") were audited by the defendant Internal Revenue Service (the "IRS") for the period January 1, 1986 through December 17, 1989. This audit resulted in a reconstruction...
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