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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.
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