District Court, D. Oregon January 4, 1996, Civil No. 95-608-MA (Spires v. United States)

ORDER

MARSH, Judge.

On October 27, 1995, I granted plaintiffs’ motion for summary judgment finding that the parties had settled a tax dispute. In so finding, I rejected the government’s argument that the settlement was non-binding because the IRS never issued closing docu*141merits. Plaintiffs now seek attorney fees pursuant to 26 U.S.C.