-3-
hold petitioner is, to the extent set out below. (2) Whether the
amounts of administrative and litigation costs claimed by
petitioners are reasonable, within the meaning of section
7430(c)(1). We hold that in part they are not and adjust the
amounts as provided below.
FINDINGS OF FACT
During 1990, the year at issue, petitioner and Hashimoto
were wife and husband, and filed a joint Federal income tax
return (Form 1040) for that year. At the time the petition in
this case was filed, petitioner and Hashimoto were divorced and
petitioners resided in Marietta, Georgia.
During the year at issue, petitioner was the sole
shareholder and president of Associated Services of Accountable
Professionals, Ltd. (ASAP), in addition to being a licensed nurse
and an attorney. Hashimoto has 2 years of college education and
previously was engaged with petitioner in other business
enterprises. Although Hashimoto was the corporate secretary of
ASAP, his duties were mainly moving furniture, changing locks,
and other maintenance work for which he was paid by the hour.
ASAP was incorporated in 1986 under the laws of the State of
Georgia, and elected to be an S corporation on March 15, 1989.
ASAP is in the business of providing nurses to hospitals and
other health care facilities (the clients) at an agreed upon
hourly rate. After the nurses have worked their shifts for the
clients, ASAP pays the nurses, and bills the clients at the
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