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for both petitioner’s and the general group’s accounts lack
detailed information regarding the number of Hoyt investor
clients who participated in the fee arrangement in each of the
relevant months, it is impossible to verify that the generic
monthly charges for group fees that appear on the records for
petitioner’s individual account are reasonable and were
reasonably allocated among petitioner and the other Hoyt investor
clients.25
Petitioner bears the burden of proving that the amount of
costs claimed is reasonable. See Rule 232(e); Powers v.
Commissioner, 100 T.C. 457, 491 (1993), affd. in part, revd. in
part and remanded 43 F.3d 172 (5th Cir. 1995). We conclude that
because petitioner has failed to fully substantiate her claim for
a share of the general group’s fees, she is entitled to recover
only a portion of the amount she claims. For purposes of
computing the amount petitioner is entitled to recover, we shall
assume that the composition of the general group of Hoyt investor
clients remained constant at its greatest size, 97, throughout
the 14-month period that petitioner participated in the group fee
arrangement. Accordingly, we award petitioner $1,348.69, which
25Had petitioner produced documentation for each month that
showed the number of clients who shared the fees, such as a
spreadsheet similar to that produced for the January 2004 fee
allocation, we could have properly determined whether the amount
of costs petitioner claims was reasonable.
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