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fees charged by attorneys with similar experience. Petitioner
has failed to establish that Mr. Urquhart possessed any nonlegal
or technical abilities apart from his expertise in the field of
tax law. Powers v. Commissioner, supra at 183. Petitioner,
therefore, has failed to establish that a special factor existed
which justifies an award in excess of the maximum rate provided
in section 7430(c)(1)(B)(iii).
We now turn to petitioner's request for an award of costs
with respect to the accounting fees. Respondent's argument that
the accounting fees are not reasonable appears to be directed to
the limitation under section 7430(c)(1)(B)(iii) as applied to
attorneys.12 It is clear that section 7430(c)(1)(B)(iii) relates
to fees paid to attorneys. Petitioner did not direct the Court
to a specific statutory authority for an award of accountant's
fees. Moreover, petitioner did not respond to respondent's
argument that the limitation of section 7430(c)(1)(B)(iii) should
apply to the accountant's fees. Respondent, on the other hand,
suggests that the limitation applies without the citation of any
authority.
Section 7430(c)(3) provides that fees for the services of an
individual (whether or not an attorney) who is authorized to
practice before the Tax Court or before the Internal Revenue
12 As previously noted, since the hourly fee charged to Ms.
Zimmerman is less than the cap (adjusted for inflation), we deem
that portion of the accountants' fees to be conceded.
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