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is not clear from that vague statement what costs petitioner
incurred and is seeking to recover. Petitioner has been pro se
throughout the proceedings and has not paid for the services of
any attorneys. It is well settled that a taxpayer cannot recover
attorney’s fees for representing herself, even if she happens to
be an attorney, which petitioner is not. Frisch v. Commissioner,
87 T.C. 838 (1986).
If it is living expenses for which petitioner seeks
reimbursement, living expenses are not costs for which section
7430(c) allows recovery. Section 7430 does not provide for the
recovery of a taxpayer’s living expenses; she would have incurred
those expenses whether she was contesting her tax liability or
not. Petitioner’s lack of income from a job to pay living
expenses and the resulting need to borrow from her parents, the
possible adverse effect of the tax lien on her credit and ability
to obtain employment, identify the so-called consequential
damages for which neither section 7430 nor any other relevant
statutory provision allows relief. See Weiner v. IRS, 986 F.2d
12, 13 (2d Cir. 1993).
Petitioner has also requested $186 for long-distance calls
to respondent’s Ogden, Utah, and Phoenix, Arizona, offices,
postage, photocopying, and typewriter rental costs. However,
petitioner provided no receipts or other substantiation and no
allocation of the total cost among the various items. Had
petitioner prevailed on the “substantially justified” and
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