Laura E. Austin - Page 29

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          expert witnesses' fees to be reasonable, and they are awarded to            
          petitioner.                                                                 
               Petitioner seeks reimbursement for $125 paid to Susan                  
          Anderson (Anderson), a staff nurse who did business with ASAP               
          from 1993 through 1995.  Anderson testified as a witness at                 
          trial; however, her testimony was not relevant because she had no           
          relationship with ASAP for the year at issue.  Thus, we find the            
          costs claimed for Anderson's services are not reasonable                    
          litigation costs.                                                           
               D.   Legal Research Costs                                              
               Petitioner submitted an itemized statement from Stephen                
          Joseph (Joseph) for legal research he performed on October 19,              
          1995, and April 8 through April 11, 1996.  The invoices indicate            
          Joseph has a J.D. degree and that he charged petitioner for a               
          total of 20 hours at an hourly rate of $50 to research the method           
          of accounting issue.  This Court has awarded fees for paralegal             
          and law clerks and for LEXIS computer research.  Powers v.                  
          Commissioner, supra at 493.  In Powers v. Commissioner, supra, we           
          determined an hourly rate of $50 was not unreasonable for a                 
          paralegal.  Accordingly, we allow $1,000 for legal research                 
          costs.                                                                      
               E.   Interest Award                                                    
               Petitioner claims interest on the amount of the costs she is           
          awarded.  The Supreme Court has consistently held that "interest            






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