If the government has to pay out thousands or tens of thousands of dollars in attorneys fees for behavior it cannot predict then we are wasting tax money. Sure the individual taxpayer wins, but the rest of the taxpayers lose. We need an honest system, but penalizing the government for acting in good-faith may not be the best answer. If a jury or judge finds a valuation to be excessive, the value should be reduced and any taxes paid should be refunded. Forcing the government to deplete its resources by paying attorneys fees for acting in a reasonable manner hurts all taxpayers and does little to correct bad behavior.