- 7 -
hours3) is the appropriate amount allocated to the FLP issue.
The following chart represents the petitioners’ proposed
allocation of hours:
FLP Valuation
(hours) (hours)
Jeffrey A. Schumacher (expert) 0 77.95
00
Subtotal-Jeffrey A. Schumacher 77.95
Harold A. Chamberlain (lead attorney)
Pleadings 30 0
Summary judgment 7 0
Expert witness 0 31
Conference with district counsel 21 1
Pre-trial prep/memorandum/motions 77 15
Trial-day 1 10 0
Trial-day 2 10 2
Briefing and posttrial review 106 0
Review respondent’s posttrial brief3 0
Motion 40 0
40304
Subtotal-Harold A. Chamberlain 49
Michael C. Riddle, Esq. (attorney)
Conferences with Chamberlain 37 0
Trial-Day 1 10 0
Trial-Day 2 10 2
1057
Subtotal-Michael C. Riddle 2
Total (489.95 hours) 361 128.95
Petitioners allocated 106 hours to the FLP issue relating to
briefing and posttrial review by Chamberlain. This allocation is
unreasonable because the parties’ findings of fact predominantly
deal with valuation and more than 80 percent of their brief is
dedicated to valuation. Moreover, the portion of the brief
dedicated to the FLP issue merely references Knight v.
Commissioner, 115 T.C. 506 (2000), and Estate of Strangi v.
Commissioner, 115 T.C. 478 (2000), revd. on other grounds 293
F.3d 279 (5th Cir. 2002), which are decisions in which the Court
held that an FLP is not disregarded for tax purposes. Under
3 Respondent, however, neglected to exclude 47 hours of
time that petitioners allocated to the valuation issue.
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Last modified: May 25, 2011