Laura E. Austin - Page 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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