MEMORANDUM OPINION
LARO, Judge:
Petitioners move the Court under section 7430 for an award of $12,296 in litigation costs. Respondent objects thereto and has filed with the Court a memorandum (respondent's memorandum) in support of his objection. We must decide whether respondent's positions in this proceeding were substantially justified. We hold they were not to the extent discussed herein and award petitioners $1,844 of litigation costs. Unless otherwise...
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