Victor E. Van Duzer, and Jane N. Van Duzer v. Commissioner of Internal Revenue

9 F.3d 1555 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. Victor E. VAN DUZER, and Jane N. Van Duzer, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee. No. 92-70320. United States Court of Appeals, Ninth Circuit. Argued and Submitted Oct. 6, 1993. Decided Oct. 14, 1993. Before: HUG, FARRIS, and BRUNETTI, Circuit Judges. 1 MEMORANDUM * 2 Victor and Jane Van Duzer appeal from the Tax Court's order denying their motion for reasonable litigation and administrative costs under 26 U.S.C. § 7430 . We have jurisdiction over the timely appeal pursuant to 26 U.S.C. § 7482 . We affirm. 3 The sole issue is whether the position of the United States in Van Duzer's tax redetermination suit was "substantially justified." 26 U.S.C. § 7430 (c)(4)(A)(i). The phrase "substantially justified" means "justified to a degree that could satisfy a reasonable person." Pierce v. Underwood, 487 U.S. 552, 565 (1988); Huffman v. Commissioner, 978 F.2d…