Deborah A. Cole - Page 15

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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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