-6-
to the recent death of her grandmother and the sudden request by
her attorney, David L. Britt, Jr. (Britt), to withdraw due to his
ill health. By February, Britt had recovered sufficiently to
resume representation of petitioner, and this consolidated case
came to trial in Atlanta, Georgia on February 13, 1996. Shortly
before trial, however, respondent conceded the computer software
issue, and petitioners conceded the travel expense issue. Thus,
the only issues remaining for decision at trial were the method
of accounting issue; whether the addition to tax under section
6662(a) should attach; and, whether Hashimoto was entitled to
innocent spouse relief pursuant to section 6013(e).
On September 16, 1996, Britt moved to withdraw as counsel
for petitioner. We granted Britt's motion on October 2, 1996,
and petitioner proceeded pro se.
On November 27, 1996, the parties filed a stipulation of
settlement. In the settlement, respondent conceded the method of
accounting issue and the additions to tax under section 6662(a),
and Hashimoto conceded that he was not an innocent spouse under
section 6013(e). The parties stipulated that the 1990 deficiency
is $4,898, which is attributable to petitioners' concession of
deductions for travel and entertainment expenses.
Accordingly, the parties settled all issues in the case
other than litigation and administrative costs. On November 27,
1996, petitioners timely moved for an award of reasonable
administrative and litigation costs. Rule 231(a)(2)(C).
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