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For costs incurred on or before January 18, 1999, reasonable
administrative costs include only those costs incurred on or
after the earlier of (1) the date of the receipt by taxpayer of
the notice of decision of the IRS Office of Appeals, or (2) the
date of the notice of deficiency. See sec. 7430(c)(2).
Litigation costs are those incurred in connection with a
judicial proceeding. See sec. 7430(a)(2), (c)(1). Reasonable
litigation costs consist of reasonable court costs, the
reasonable expenses of necessary expert witnesses, the reasonable
cost of any necessary study, analysis or report, and reasonable
fees paid or incurred for the services of attorneys. See sec.
7430(c)(1).
Rule 232(d)(1) requires that, if the parties disagree as to
the reasonable amount of attorney's fees, counsel for the party
moving for such fees and costs submit, among others, a detailed
summary of the time expended by each individual for whom fees are
sought, including a description of the nature of the services
performed during each period of time summarized.
The billing statements, in large part, do not indicate on
which of the issues each of the attorneys and the paralegal
worked in each time period. Accordingly, we approximate
petitioners' costs incurred in connection with the Diplomat
Associates losses, bearing heavily against petitioners whose
inexactitude is of their own making. See Cohan v. Commissioner,
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