- 11 - the amount of $13,314.33. The litigation and administrative costs petitioner claims were computed using an hourly rate of $195 for two of petitioner’s attorneys and included a claim of $7,121.37 for petitioner’s alleged share of attorney’s fees (the group fees) that her attorneys had charged to two groups of similarly situated Hoyt investor clients with pending section 6015 claims. In support of the motion, petitioner’s counsel attached billing records for petitioner’s account dated September 10, 2002, to April 16, 2004, that described in detail the attorney’s fees and costs petitioner incurred individually and contained generic entries4 denoting monthly charges to petitioner’s account for her alleged share of the group fees. Although petitioner alleged that the group fees were reasonable and that her share of the group fees had been reasonably allocated to her, she did not include any supporting information or documentation with respect to the group fees that showed the nature of the work performed, the attorneys’ hourly rates, the identity of the person who performed the work, the number of hours billed for the work, the number of Hoyt investor clients who shared in the group fees, or the manner in which the group 4Although petitioner agrees that the fee summary for her account attached to the motion describes her share of the “Group Innocent Spouse fees” as “flat” fees, petitioner contends that the flat fee reference is simply the way in which the Pearson- Merriam (petitioner’s attorneys’ law firm) billing program describes sum certain fees. Petitioner’s representation is supported by a declaration of petitioner’s counsel.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011