109 T.C. No. 10 UNITED STATES TAX COURT ROBERT T. COZEAN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 19318-95. Filed October 15, 1997. Prior to trial, R conceded the deficiencies determined for the years 1990 through 1992. P filed a timely claim for an award of litigation costs, including, among other things, attorney's fees billed at $250 per hour and one accountant's fees billed at $170 and $175 per hour and another's fees billed at $90 and $92 per hour. R concedes that P has satisfied all the requirements for entitlement to litigation costs and disputes only the amounts of the fees claimed by the attorney and the principal accountant. Specifically, R asserts that the limitation of sec. 7430(c)(1)(B)(iii), I.R.C., of $75 per hour (adjusted for inflation) for the years in issue, applies to all fees claimed. Held: P failed to establish that a special factor existed which justifies an award of attorney's fees in excess of the $75 limitation (adjusted for inflation).Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
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