MEMORANDUM OPINION AND ORDER DENYING MOTION FOR COSTS AND ATTORNEY FEES
McKEAGUE, District Judge.
On September 8, 1999, the Court entered a judgement and a "Stipulation and Order for Dismissal of Action and Release of Escrowed Funds" holding that plaintiff had substantially prevailed with respect to the most significant issue in this case. On October 5, 1999, plaintiff moved for an award of costs and attorney fees under 26 U.S.C. § 7430, contending...
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