9
parties stipulated that petitioner had deficiencies in income tax
of $18,208 for FY 1992, $8,124 for FY 1993, and $6,388 for FY
1994, that petitioner is not liable for accumulated earnings tax
for those years, and that petitioner is not liable for additions
to tax for those years.
G. Petitioner's Litigation Costs
Petitioner filed a motion for an award of litigation and
administrative costs on September 15, 1997. Petitioner incurred
attorney's fees and other costs for services performed in this
matter from June 14, 1996, to December 12, 1997, as follows:
Date of services Fee Attorney hours Costs
1996:
June 5-21 $1,650 5.5 --
June 28-July 17 3,540 11.8 --
July 20-Aug. 16 1,110 3.7 --
Aug. 27-29 1,050 3.5 $144.48
Nov. 8-21 900 3.0 --
Dec. 11-16 1,170 3.9 --
1997:
Jan. 6 90 .3 --
Jan. 27 30 .1 --
Apr. 15-25 510 1.7 --
Apr. 28-May 23 7,740 25.8 --
May 27-June 24 3,870 12.9 --
June 26-July 16 4,530 15.1 --
July 30-Aug. 25 570 1.9 --
Aug. 26-Sept. 26 9,060 30.2 --
Sept. 29-Oct. 18 1,080 3.6 --
Nov. 10-18 480 1.6 --
Nov. 26-Dec. 12 3,600 12.0 --
Total 40,980 136.6 144.48
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