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There is no evidence in the record of a notice of decision
by the Office of Appeals. For purposes of the administrative
proceedings in this case, respondent's position is that which was
articulated in the notice of deficiency, issued on September 30,
1996. For purposes of the court proceedings in this case,
respondent's position is that which is set forth in the answer to
the amended petition on April 11, 1997.
We now consider the administrative costs issue. Petitioner
failed to comply with the requirements of Rules 231(d) and 232(d)
even though he asserted in his motion that he had read Rule 232.
He did not provide us with the detailed information required
under the Rules. Thus, we are presented with a motion which on
its face contains mere estimates. Without more, we cannot say
that these costs are reasonable. In fact, we believe some of the
costs are patently unreasonable, e.g., $2,200 for photocopying.
There is no indication in the record that any attorney or C.P.A.
was involved in this case. We have long held that fees
recoverable under section 7430 do not include a pro se litigant's
own time, even if that person should be an attorney. Frisch v.
Commissioner, 87 T.C. 838 (1986). On this record, we cannot find
that petitioner incurred "reasonable administrative costs" within
the meaning of section 7430.
Further, in the notice of deficiency, respondent determined
a deficiency based on the net worth method, made other
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