MEMORANDUM FINDINGS OF FACT AND OPINION
COLVIN, Judge:
This matter is before the Court on petitioner's motion for litigation costs under section 7430 and Rule 231.
To prevail, petitioner must show that respondent's position in the underlying litigation was not substantially justified. We conclude that petitioner has not made this showing. Thus, petitioner's motion will be denied.
The parties have submitted affidavits and memoranda supporting...
Let's get started
Welcome to the leading source of independent legal reporting
Sign on now to see your case.
Or view more than 10 million decisions and orders.
- Updated daily.
- Uncompromising quality.
- Complete, Accurate, Current.