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Supporting affidavits submitted by petitioners indicate that the
administrative services rendered date as far back as August 2000.
The affidavits also show, however, that GTWP did not bill
petitioners for any of these services or for any of the
miscellaneous expenses before October 31, 2003, some 6 months
after petitioners filed their motion for reasonable litigation
and administrative costs and shortly after this Court ordered
petitioners to provide additional support for their claimed
costs.11 Ms. West’s affidavit states: “These invoices have been
incurred but not yet been paid by Victor and Judith A.
Grigoraci.”
Petitioners have not persuaded us that they were legally
obligated, or were even expected, to pay the invoiced amounts.
Indeed, petitioners represent that “any fees and expenses paid by
the Internal Revenue Service to the Petitioners will promptly be
paid to Grigoraci, Trainer, Wright & Paterno.” From this
statement, and absent any suggestion to the contrary, we infer
that petitioners will not pay any expenses to GTWP unless and
until this Court awards costs under section 7430.12 In these
11 Ms. West’s affidavit states that on Oct. 31, 2003, she
prepared invoices from GTWP to petitioners for the administrative
personnel expenses and miscellaneous costs at issue and that on
Nov. 3, 2003, she prepared an invoice of $240 for the costs of
preparing petitioners’ reply to respondent’s response.
12 In fact, the record does not suggest that the
administrative services performed on petitioners’ behalf by GTWP
(continued...)
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Last modified: May 25, 2011