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001882P.pdf   06/29/2001  Linda Marie Sherbo  v.  CIR
   U.S. Court of Appeals Case No:  00-1882
   Agency   
   Civil case- federal tax. Commissioner's policy of issuing deficiency 
   notices to both taxpayers when they both claim a benefit to which 
   only one is entitled and denying the benefit to both until the 
   rightful claimant can be determined is substantially justified as 
   it is not unreasonable to require the taxpayer to corroborate 
   her position and establish her claim to the benefit; taxpayer 
   who established her entitlement to the benefit was not entitled 
   to attorneys's fees.