Basr Partnership v. United States
Court of Appeals for the Federal Circuit
1Opinion of the Court
Dissenting opinion filed by Circuit Judge Wallach.
Prost, Chief Judge.
This appeal concerns an order from the U.S. Court of Federal Claims awarding $ 314,710.69 to BASR Partnership ("BASR") under 26 U.S.C. § 7430 (" I.R.C. § 7430") for its reasonable litigation costs incurred in connection with a tax determination from a Tax Equity and Fiscal Responsibility Act of 1982 ("TEFRA") proceeding. The United States ("Government") appeals the order. We have jurisdiction pursuant to 28 U.S.C. § 1295(a)(3). We affirm.
I
The Pettinati family owned a commercial printing company, Page Printing, from 1982…
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