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motion for summary judgment. We fail to see the relevance of
this argument. The fact that the payment was made by the clerk
is not determinative as to whether the payment was alimony. If
the payment had been made by Human directly to petitioner, it
still would have been in the nature of a property settlement.
Accordingly, respondent has failed to carry the burden in
establishing that the position in the judicial proceeding was
substantially justified.
Issue 2. Reasonable Administrative and Litigation Costs
Petitioner seeks recovery of reasonable litigation and
administrative costs that she incurred. We have observed that
"'So long as the government's position justifies recovery of
fees, any reasonable fees to recover such fees are recoverable.'"
Galedrige Constr., Inc. v. Commissioner, T.C. Memo. 1997-485
(quoting Huffman v. Commissioner, 978 F.2d at 1149). Thus, the
fees incurred by petitioner for her motion for reasonable
litigation and administrative costs are recoverable. We must
decide whether the number of hours billed, the rate at which
those hours were billed, and the miscellaneous costs are
reasonable as claimed by petitioner.
Fees of Attorney Stephen C. Beeler
Petitioner submitted an itemized statement from her
attorney, Beeler, for the hours that were spent on the case from
October 23, 1996, through November 18, 1997. Beeler billed his
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