Laura E. Austin - Page 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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