- 31 - Respondent does not object to the reasonableness of the costs petitioner claims for the services of legal assistants, contract assistance, filing fees, postage, and online research that were charged to her individual account. Consequently, we award petitioner those costs in the amount of $1,350.34.22 4. Allocation of Group Fees We next decide whether the attorney’s fees and costs for petitioner’s share of the group fees are reasonable and were reasonably allocated among petitioner and the other Hoyt investor clients. Section 7430(a) authorizes an award of reasonable administrative and litigation costs incurred in connection with an administrative or court proceeding brought by or against the United States with respect to the determination, collection, or refund of any tax. In order for costs, including attorney’s fees, to qualify as reasonable litigation or administrative costs, they must come within the relevant definitions, sec. 7430(c)(1) and (2), and they must be incurred in connection with a qualifying proceeding. 22This figure includes the following costs: $772.50 for legal assistants, $500 for contract assistance, $60 Tax Court filing fee, $5.84 for postage, and $12 for online research. Only costs for the services of an individual who is admitted to practice before this Court or the Internal Revenue Service may be awarded as attorney’s fees. Sec. 7430(c)(3)(A). We award fees for work performed by legal assistants, therefore, as costs, rather than as attorney’s fees. See Fields v. Commissioner, T.C. Memo. 2002-320; O’Bryon v. Commissioner, T.C. Memo. 2000-379.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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