-18-
is reasonable and therefore shall award fees for 25 percent of
these hours allocable to the section 6661 issue. Sec.
7430(c)(1)(A).
2. 1995
Petitioner's attorney billed 60.1 hours for 1995, 15 hours
of which were related to the section 6661 issue. We find this
amount of time is reasonable and therefore shall award fees for
these hours.
3. 1996
Petitioner's attorney billed 67.2 hours for 1996, 16.8 hours
of which were related to the section 6661 issue. We find this
amount of time is reasonable and therefore shall award fees for
these hours.
4. 1997
Petitioner's attorney billed 19.2 hours for the time
incurred in researching, preparing, and filing petitioner's
motion for reasonable litigation costs. We find this amount of
time is reasonable and therefore shall award fees for these
hours.
B. Miscellaneous Litigation Costs
The itemized billing shows $20 of miscellaneous costs for
photocopying and the apportioned filing fee. We find this amount
to be reasonable.
C. Legal Research Costs
Petitioner submitted an itemized statement for legal
research he performed on Westlaw from April 19, 1995, through
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