- 15 - 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 withPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011