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dispute over the $703.50 check did not unreasonably protract the
administrative and Court proceedings.
IV. Reasonableness of Fees Claimed
Section 7430(c) defines reasonable litigation and
administrative costs as including: (1) Reasonable court costs;
(2) administrative fees charged by the IRS; (3) certain costs
related to expert witnesses and production of reports; and (4)
reasonable fees for the services of an attorney. Recoverable
attorney's fees are limited to a maximum of $75 per hour adjusted
for cost of living increases and special factors. Sec.
7430(c)(1) and (2).
Petitioner seeks reimbursement for $3,075 of her attorney's
fees. Respondent contends that a majority of these fees related
to the dispute over the year in which the $703.50 check was
includable. While petitioner does not refute this contention,
the record reveals that respondent did not take a position
relating to the $703.50 check until June or July of 1995.
Therefore, all attorney's fees incurred prior to this period are
recoverable. The stipulation, however, does affect the total
amount of recoverable fees. Accordingly, we award petitioner
$2,125 for her attorney's services.
In addition, petitioner claims reimbursement for expenses of
$132.95, relating to photocopies ($25), phone calls ($13),
postage ($16.54), fax charges ($5.41), Federal Express charges
($13), and her Tax Court filing fee ($60). With the exception of
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