Bowles v. United States

*454MEMORANDUM OPINION

MICHAEL, District Judge.

The plaintiffs herein, Michael and Lynn Bowles, have asked the court to enter an order awarding them costs and attorney’s fees pursuant to 26 U.S.C. § 7430. Both parties have submitted briefs supporting their respective positions regarding such an award and, upon due consideration, the matter is ripe for disposition.

7. Background

Because an award of fees depends largely on the parties’ behavior during the litigation, a thorough discussion of the case history is appropriate. In 1983, the Bowles sued the United States under 28 U.S.C. § 1346(a)(1) to…