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Franchise Tax Board, and to finalize a will. That work was not
related to this case. We do not award fees for these hours.
Bode v. United States, supra at 1047-1048. Shannahan billed
123.5 hours for services related to this case. We find this to
be reasonable. Thus, we award petitioner attorney's fees of
$13,585 (123.5 hours at $110 per hour).
b. Accountant's Fees
Petitioner's accountant billed 98.5 hours at $25 per hour to
analyze accounts receivable, earnings and profits, accumulated
earnings, petitioner’s Bardahl computation, petitioner's cash
deposit journal relating to dividends, and rent expenses, and to
meet and correspond with petitioner and petitioner's counsel.
Respondent contends that some of the accountant's activities are
unrelated to petitioner's accumulated earnings tax issue. We
agree with respondent in part. Petitioner's accountant billed 12
hours to analyze rent expenses and to "return minutes book to
attorney". These services were apparently not related to this
case. We do not award fees for these hours. Bode v. United
States, supra at 1047-1048. Petitioner's accountant billed 86.5
hours for services related to this case. We find this to be
reasonable. We award petitioner accountant's fees of $2,162.50
(86.5 hours at $25 per hour).
Petitioner also seeks reimbursement of $144.48 for other
costs ($60 for the filing fee and $84.48 for registered mail and
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