Tae M. Kim and Young J. Kim appeal from the tax court’s orders: (1) granting summary judgment to the Commissioner on the Kims’ action seeking recovery of administrative costs under 26 U.S.C. § 7430(f)(2) (2000) and (2) denying their motion for reconsideration. Our review of the record and the tax court’s opinions discloses no reversible error. Accordingly, we affirm on the reasoning of the tax court. See Kim v. Commissioner, Tax Ct. No. 01-1448 (U.S. Tax Ct. Feb. 21, 2002; Mar. 26, 2002). We dispense with oral argument because the facts and legal contentions are adequately presented in the materials before the court and argument would not aid the decisional process.

AFFIRMED.