John J. Petito - Page 15




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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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