3
(3) Whether the number of hours billed by petitioner's
counsel and accountant and petitioner's other litigation costs
were reasonable. We hold that they were to the extent set out
below.
The parties submitted memoranda and affidavits supporting
their positions. We decide the motion on the basis of those
memoranda and affidavits. Neither party requested a hearing. We
conclude that a hearing is not necessary to decide this motion.
Rule 232(a)(3).
Background
A. Petitioner
Petitioner is a corporation the principal place of business
of which was in San Diego, California, during the years in issue
and when it filed its petition. Petitioner reports its income
using the cash method of accounting. Petitioner is in the
business of cleaning military and civilian ships.
B. Petitioner's 1992, 1993, and 1994 Tax Returns
Petitioner timely filed U.S. corporate income tax returns
(Forms 1120) for its tax years ending on September 30, 1992,
1993, and 1994,3 on which it reported the following:
3 Petitioner's 1992, 1993, and 1994 fiscal years ended on
Sept. 30.
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