Section 280-RICR-20-00-1.8 - Disallowance of AwardsA. No award of fees or expenses may be made if the adjudicative officer finds that the Division of Taxation was substantially justified in the actions leading to the proceeding and in the proceeding itself.B. The adjudicative officer may, at his/her discretion, deny fees or expenses if special circumstances make an award unjust.C. Notice of the decision disallowing an application for an award of fees and expenses shall include written findings and conclusions with respect to the denial of the award and shall be sent to the party by the Division of Taxation via regular mail.280 R.I. Code R. § 280-RICR-20-00-1.8