Foothill Ranch Company Partnership, Buck Equities, Ltd., Tax Matters Partner - Page 12

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          costs attributable to services performed by individuals (e.g.,              
          paralegals and law clerks) under the supervision of someone who             
          was authorized to practice before the Court or IRS.  See, e.g.,             
          Powers v. Commissioner, 100 T.C. 457, 492-493 (1993), affd. in              
          part, revd. in part and remanded 43 F.3d 172 (5th Cir. 1995).               
          The costs claimed by petitioner are attributable to services                
          performed by individuals who meet these requirements.                       
          Accordingly, petitioner is eligible to receive an award for such            
                    2.   Reasonable Fees                                              
               Section 7430(c)(1)(B)(iii) limits the hourly rate for                  
          attorney's fees to $75, with allowance for a higher rate for                
          increases in the cost of living and other special factors (e.g.,            
          the limited availability of qualified attorneys).                           
                         a.  Special Factors                                          
               Petitioner contends that it is entitled to fees in excess of           
          the statutory rate because (1) petitioner's advisers had special            
          expertise in real estate and tax law, and (2) the prevailing rate           
          in the Los Angeles area exceeds $75.  To qualify for a higher               
          statutory rate, the attorney must have tax expertise that is                
          necessary for the litigation in question.  Pierce v. Underwood,             
          487 U.S. 552, 572 (1988); Huffman v. Commissioner, 978 F.2d 1139,           
          1149-1150 (9th Cir. 1992), affg. in part and revg. in part T.C.             
          Memo. 1991-144; Powers v. Commissioner, 100 T.C. at 489.                    
          Petitioner has failed to meet this standard.  In addition, the              

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