- 9 -
hours and costs that the attorney did not allocate to specific
issues.
Petitioners' attorney billed a total of 387.6 hours (i.e.,
206.3 hours relating to the cattle contribution, pecan tree
basis, and pruning cost issues; 13.7 hours in 1997 relating to
the cash contributions; 127.6 hours in 1997 relating to all
issues; and 40 hours in 1998 relating to all issues). An award
relating to attorney's fees incurred in 1997 and 1998 is limited
to the statutory rate of $110 and $120 per hour, respectively.
Sec. 7430(c); Rev. Proc. 97-57, 1997-52 I.R.B. 20; Rev. Proc. 96-
59, 1996-2 C.B. 392. Accordingly, we award attorney's fees of
$11,490 (i.e., 1997: (13.7 + (127.6 x 53 percent)) x $110 =
$8,946; 1998: (40 x 53 percent) x $120 = $2,544; total: $8,946 +
2,544 = $11,490).
Petitioners incurred $1,816 of reimbursable litigation costs
(i.e., filing fees of $240 and fax, copy, supply, telephone, and
travel expenses totaling $1,576). We award petitioners $1,075
(i.e., $240 + ($1,576 x 53 percent)).
To reflect the foregoing,
Appropriate orders and
decisions will be entered.
Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011