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reasonableness of the allocation. The composition of the general
group of Hoyt investors varied from month to month as clients
chose to dismiss their claims or became widowed or divorced and
sought relief only under section 6015(c). Because the billing
records for both petitioner’s and the general group’s accounts
lack any factual detail 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
investors clients.25
Petitioner bears the burden of proving that the amount of
the costs claimed is reasonable. Rule 232(e); Powers v.
Commissioner, 100 T.C. at 491. 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
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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