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1995, respondent determined that petitioner was liable for a
$14,089 deficiency and a $2,817.80 accuracy-related penalty under
section 6662(a).
Petitioners retained Ms. Zatopa on or about April 5, 1999,
to serve as their representative as to the subject years. Two
months later, petitioners and Ms. Zatopa signed an agreement in
which petitioners agreed to pay Ms. Zatopa $50 an hour in
connection with this proceeding. The agreement also provided:
“If Attorney [Ms. Zatopa] is successful in overturning parts or
all of the Commissioner’s decisions, Attorney will seek to
recover attorney’s fees, if and where permitted under the
Internal Revenue Code, at the rate of $110 per hour from the
Internal Revenue Service.”
On June 15, 1999, Ms. Zatopa petitioned the Court on behalf
of petitioners to redetermine the determinations reflected in the
notices of deficiency. Respondent transferred the case to
Appeals approximately 2 months later, and Appeals settled the
case with petitioners after receiving from them additional
information. Respondent conceded all items for 1994 and all but
a $777 deficiency for 1995.
Petitioner paid Ms. Zatopa $1,325 (26.5 hours times $50 an
hour) for her work on this case.
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Last modified: May 25, 2011