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clients’ cases other than petitioner’s and, therefore, were not
“incurred in connection with” petitioner’s court proceedings as
required by section 7430(a).
Petitioner contends that an “informal survey” of local
attorneys shows that the prevailing hourly rate for attorneys
specializing in Federal tax practice in the Seattle, Washington,
area is between $225 and $350 and that billing at an hourly rate
that is less than the customary rate for similar work is a factor
that supports the reasonableness of the attorney’s fees. With
respect to her share of the group fees, petitioner contends that
the group fees were charged to a group of Hoyt investor clients,
all of whom had pending section 6015 claims, for work relating to
common legal and factual issues that directly affected or
contributed to the resolution of each client’s case. Petitioner
further contends that the group fee arrangement allowed the Hoyt
investor clients to obtain professional advice and assistance at
a reduced cost, that any services related to the development of
factual issues unique to a particular client were charged only to
the individual client, and that no client was charged for work
that did not directly benefit the client’s case.
3. Hourly Rate
We first decide whether the hourly rate for the attorney’s
fees is reasonable. In the absence of proof that a special
factor applies, petitioner may not recover attorney’s fees in
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