Vasquez

*382 MEMORANDUM **

Gilbert Vasquez appeals the decision of the Tax Court denying his motion for litigation costs under I.R.C. § 7430. 1 Because the parties are familiar with the facts, we do not recount them here, except as necessary to explain our decision. This court has jurisdiction to hear appeals from the Tax Court under I.R.C. § 7482(a)(1). This court reviews the Tax Court’s decision to grant or deny litigation costs under I.R.C § 7430 for abuse of discretion. Liti v. Comm’r, 289 F.3d 1103, 1104 (9th Cir. 2002). Under that standard, we “ ‘reverse only if we have a definite and firm conviction that the [Tax Court] committed a clear error of judgment in the conclusion it reached upon weighing the relevant factors.’ ” Id. at 1104-05 (quoting TKB Int’l, Inc. v. United States, 995 F.2d 1460, 1468 (9th Cir.1993)).

I.R.C. § 7430 provides for an award of “reasonable litigation costs” to “the prevailing party” in tax litigation suits. I.R.C. § 7430(a). A litigant cannot meet the definition of “prevailing party” if “the United States establishes that the position of the United States in the proceeding was substantially justified.” I.R.C. § 7430(c)(4)(B)(i). “Generally, the position…