Deborah A. Cole - Page 16

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          the Federal Express charges, see Cassuto v. Commissioner, 93 T.C.           
          256, 275 (1989), affd. in part and revd. in part 936 F.2d 736 (2d           
          Cir. 1991), all of the above expenses are reasonable.                       
               Consequently, petitioner is entitled to reimbursement of her           
          reasonable administrative and litigation fees and costs of                  
          $2,244.95 ($2,125.00 + 119.95).                                             
               We have considered all other arguments made by petitioner              
          and respondent and found them to be either irrelevant or without            
          merit.  Accordingly, we shall grant petitioner's Motion for Award           
          of Reasonable Administrative and Litigation Costs and Fees.                 
               To reflect the foregoing,                                              


                                                  An appropriate order and            
                                             decision will be entered.                






















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