David E. Heasley and Kathleen Heasley, Cross-Appellees v. Commissioner of Internal Revenue, Cross-Appellant
Court of Appeals for the Fifth Circuit
1Opinion of the Court
BRIGHT, Senior Circuit Judge:
David and Kathleen Heasley (The Heas-leys) appeal from the decision of the Tax Court denying a portion of their request for attorneys’ fees and litigation costs under 26 U.S.C. § 7430 (1988). The Heasleys incurred the sought-after fees and costs during prior litigation before the Tax Court and on appeal to this court. The Internal Revenue Service cross-appeals, challenging the Heasleys’ entitlement to any fee award and disputing the manner in which the Tax Court calculated the award. We affirm in part, reverse in part and remand in part.
1. BACKGROUND
The facts that…
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