-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 thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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