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notice of decision from the Commissioner’s Appeals Office, the
date of a notice of deficiency, or the date the first letter of a
proposed deficiency is sent. Inasmuch as respondent did not
issue to petitioner either an Appeals Office notice of decision
or a letter of proposed deficiency, petitioner’s claim for
administrative costs is limited to costs incurred after December
29, 1999–-the date of the notice of deficiency.
D. Reasonable Administrative and Litigation Costs
We now decide whether the amounts claimed by petitioner for
administrative and litigation costs are reasonable, and if not,
what portion of the amounts claimed should be awarded under
section 7430. Petitioner is requesting $10,500 in attorney’s
fees and $4,200 in accountant’s fees paid to Mr. Carra and Mr.
Mulcahy, respectively; $20,000 and $2,500 in attorney’s fees paid
to Fred Schwartz (Mr. Schwartz) and Richard Fish (Mr. Fish),
respectively; pro se/lost business opportunities of $40,800;
travel expenses of $3,000; telephone, copying, office supplies,
and equipment expenses of $5,500; and punitive damages of $9
million. Respondent objects to the reasonableness and amounts of
the alleged fees and expenses.
1. Attorney’s and Accountant’s Fees
a. Mr. Carra/Mr. Mulcahy
The record shows that Mr. Carra provided legal services and
Mr. Mulcahy provided accounting services to petitioner with
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Last modified: May 25, 2011