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clerical in nature. More fundamentally, even if we were to
assume, for sake of argument, that Ms. Lyons and Ms. West acted
as petitioners’ representatives, this circumstance would be
insufficient to meet the section 7430 requirement that the cost
of their services be “incurred”. See Kruse v. Commissioner,
supra; Thompson v. Commissioner, T.C. Memo. 1996-468.
In conclusion, petitioners have failed to show that they
“incurred” the claimed administrative personnel expenses or the
associated miscellaneous expenses. Moreover, they have
acknowledged that most of the claimed administrative personnel
expenses relate to the Grigoraci I proceedings and have failed to
establish how much of the claimed miscellaneous expenses relates
to this proceeding. We have found that only $60 of the claimed
filing fees relates to the instant proceedings. Giving effect to
respondent’s concession, we hold that petitioners are entitled to
an award of $60 for these filing fees.
E. Punitive Damages
Petitioners also request that we award punitive damages
against respondent. There is no statutory authority for this
Court to consider petitioners’ claim for punitive damages against
the Internal Revenue Service; consequently, we have no
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