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that $55 per hour (i.e., about half the attorney rate) would be
reasonable. We agree. See, e.g., Powers v. Commissioner, supra
at 493 (awarding paralegal fees at about half the attorney rate).
Accordingly, petitioners are entitled to a rate of $55 per hour
(i.e., for 44.7 hours).
Petitioners incurred $163 of reimbursable litigation costs
relating to photocopies, postage, Tax Court filing fee, faxes,
and telephone calls. An unsubstantiated $3.50 expense and an
$11.50 Federal Express expense shall not be reimbursed. See
Cassuto v. Commissioner, 93 T.C. 256, 275 (1989) (declining to
reimburse Federal Express expense absent proof of necessity),
affd. in part and revd. in part on another ground 936 F.2d 736
(2d Cir. 1991).
We award petitioners $9,681.
Any other contention made by the parties is irrelevant,
moot, or meritless.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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