- 2 - 2. Whether petitioners are entitled to an award of attorney’s fees at an hourly rate higher than $140. We hold that they are not. The parties submitted memoranda and affidavits supporting their positions. We decide the motion based on those memoranda and affidavits. We conclude that a hearing is not necessary to decide this motion. Rule 232(a)(2). Section references are to the Internal Revenue Code in effect for the years in issue. Rule references are to the Tax Court Rules of Practice and Procedure. Background A. Petitioners Petitioners are husband and wife who resided in California when they filed the petition. B. Dang v. Commissioner, T.C. Memo. 2002-117 Petitioners owned a grocery store (Manwah) that was failing in 1995, 1996, and 1997. About half of the purchases at Manwah were made with food stamps. Manwah was located in an economically depressed area of Los Angeles. Six of the seven grocery stores in that area had closed by the time of trial. Petitioners gave respondent’s agent daily summaries or tapes of Manwah’s sales for 331 days for 1995, 6 months for 1996, 9 months for 1997, and all of 1998.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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