Peter J. Tkac - Page 6




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          recovery of attorney’s fees for consultation outside of                     
          representation in the proceeding.  Accordingly, we agree with               
          respondent and deny petitioner’s $200 claim for legal fees                  
          because of his failure to provide sufficient detail from which              
          to determine whether the claim for legal fees is reasonable.                
               We next consider petitioner’s claim of $245 for materials              
          used in litigation and $50 for travel, postage, and copying                 
          costs.  Again, respondent argues that petitioner should not be              
          allowed to recover any costs unless they are substantiated.  In             
          addition, respondent argues that petitioner is, in any event,               
          not entitled to recover his costs for travel.  With respect to              
          travel expenses, this Court has held that such expenses are not             
          recoverable under section 7430.  Mason v. Commissioner, T.C.                
          Memo. 1998-400; Buck v. Commissioner, T.C. Memo. 1993-16.                   
          Accordingly, petitioner is not entitled to recover his mileage              
          expenses in pursuing this matter.                                           
               Section 7430 does not require any particular level of                  
          substantiation in order for a prevailing party to be entitled to            
          recover costs.  Although petitioner has not provided the Court              
          with supporting evidence of any expenditure, the Court’s file               
          does reflect that petitioner incurred expenses for postage and              
          copying expenses.  On the basis of information contained in the             
          record, we conclude that petitioner incurred $100 for copying               
          and postage.                                                                






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