John J. Petito - Page 17




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          Consequently, petitioner is entitled to an award in this matter             
          of $3,640 for reasonable attorney’s fees (26 hours x $140 per               
          hour).                                                                      
               2.  Pro Se Expenses/Opportunity Costs                                  
               Petitioner is not entitled to recover costs for the value of           
          his pro se services.  We have held that a pro se attorney may not           
          recover fees for the value of his own services because lost                 
          opportunity costs are not fees paid or incurred for the services            
          of an attorney within the meaning of section 7430.  Frisch v.               
          Commissioner, 87 T.C. 838, 844-846 (1986).  Thus, the $40,800               
          that petitioner claims for the value of the time that he spent              
          representing himself in this matter constitutes “opportunity                
          costs” which are not costs which may be awarded under section               
          7430.                                                                       
               3.  Travel Expenses                                                    
               Mileage and parking fees incurred while traveling to and               
          from the various hearings in this matter are not expenses which             
          fall within the purview of section 7430.  See Mason v.                      
          Commissioner, T.C. Memo. 1998-400.  Accordingly, petitioner is              
          not entitled to an award for travel expenses.                               
               4.  Miscellaneous Expenses                                             
               Although telephone, copying, and office supply expenses may            
          be reimbursable administrative or litigation costs under section            
          7430, see Schaefer v. Commissioner, T.C. Memo. 1991-426,                    






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