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issues presented in the case, or (3) local availability of tax
expertise. Sec. 7430(c)(1)(B)(iii).
Pursuant to Rule 232(d), if the parties disagree as to the
amount of reasonable attorney’s fees, the moving party must
submit an additional affidavit which includes, in relevant part,
(1) a detailed summary of the time expended by each individual
for whom fees are sought, including a description of the nature
of the services performed during each period of time, (2) a
description of the fee arrangement with the client, (3) a
statement whether a special factor exists that justifies a rate
in excess of the statutory limit, and (4) any other information
that will assist the Court in evaluating the award of costs and
fees.
The amount of petitioner’s claim for litigation costs
includes the costs of professional services that were charged by
her attorneys to her individual account and her share of group
fees that were charged to common accounts for the benefit of
several Hoyt investor clients, including petitioner. The fees
and costs petitioner claims are summarized as follows:
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