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Accordingly, petitioners are entitled to a rate of $55 per hour
(i.e., for 44.8 hours).
Petitioners incurred $183 of reimbursable litigation costs
relating to postage, photocopies, telephone calls, faxes, and Tax
Court filing fee. 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 $10,798.
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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Last modified: May 25, 2011