20. If a U.S. Tax Court agrees with the taxpayer on appeal that the IRS position was largely unjustified, which of the following is correct?

a. The taxpayer must still pay administrative and litigation costs.

b. The taxpayer may recover administrative but not litigation costs.

c. The taxpayer may recover litigation but not administrative costs.

d. To be eligible to recover some of the administrative and litigation costs, the taxpayer must have tried to resolve the case administratively, including going through the appeals process, and must have given the IRS the information necessary to resolve the case.

e. None of the above