Tsa/the Stanford Associates, Inc. v. Commissioner Internal Revenue Service, Martha G. Price Lewis E. Graham, II v. Commissioner Internal Revenue Service

77 F.3d 490 77 A.F.T.R.2d 96 -823, 96-1 USTC P 50,156 NOTICE: Ninth Circuit Rule 36-3 provides that dispositions other than opinions or orders designated for publication are not precedential and should not be cited except when relevant under the doctrines of law of the case, res judicata, or collateral estoppel. TSA/THE STANFORD ASSOCIATES, INC., Petitioner-Appellant, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. Martha G. PRICE; Lewis E. Graham, II, Petitioners-Appellants, v. COMMISSIONER INTERNAL REVENUE SERVICE, Respondent-Appellee. Nos. 94-70359, 94-70360. United States Court of Appeals, Ninth Circuit. Argued and Submitted Dec. 6, 1995. Decided Feb. 6, 1996. 1 Before: WALLACE and THOMPSON, Circuit Judges, and SEDWICK, District Judge. * 2 MEMORANDUM ** 3 Martha G. Price and Lewis E. Graham, II, and Graham's business, TSA/The Stanford Associates, Inc. (Taxpayers), sought attorney fees and costs under the Internal Revenue Code, 26 U.S.C. § 7430 (Code), for obtaining a redetermination of a tax deficiency issued by the Commissioner of the Internal Revenue Service (Commissioner). The tax court held the Taxpayers were not entitled to attorney fees and costs…