- 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
Last modified: May 25, 2011