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November 27, 1995, was for a "telephone conference with the
United States Court of Appeals re: rules and admission". The
record does not show why such a call was necessary, why
petitioners' attorney would need the rules of, or to be admitted
to, a Court of Appeals, or which Court of Appeals the paralegal
called. We shall not award fees for this time. Three-tenths
(0.3) of one hour, billed on March 19, 1996, relates to the
pension issue. We shall not award fees for this time. We find
the remaining 32.1 hours listed on the itemized statement to be
reasonable in amount; therefore, we award 80 percent of these
hours.
Petitioners also requested an additional 5 hours of
paralegal's fees which were not listed on the itemized statement.
Petitioners presented no detailed explanation of the services
provided during these hours. We shall not award fees for these
hours. Rule 231(d); Powers v. Commissioner, 100 T.C. at 492.
5. Miscellaneous Litigation Costs
Petitioners request reimbursement for $24.20 in costs
related to "Federal Express". Petitioners have offered no reason
for their attorney's use of Federal Express instead of the U.S.
Postal Service. Petitioners have failed to prove the necessity
of such costs, and we shall not award any litigation costs for
these expenses. See Cassuto v. Commissioner, 93 T.C. 256, 275
(1989), affd. in part and revd. in part on other grounds 936 F.2d
736 (2d Cir. 1991).
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