Thousand Oaks Residential Care Home I, Inc., et al. v. Comr., T.C. Memo. 2013-156

(petitioner prevailed in initial case (T.C. Memo. 2013-10) on issue of reasonableness of compensation, but IRS claims petitioner not entitled to administrative and litigation costs; court agreed with IRS because IRS position was substantially justified; reasonableness of compensation is a question of the facts and circumstances). 

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