Barbara A. Owen - Page 30

                                       - 30 -                                         
          was performed, and (2) the fees were charged for work that                  
          contributed to the resolution of clients’ cases other than                  
          petitioner’s and, therefore, were not “incurred in connection               
          with” petitioner’s administrative and court proceedings as                  
          required by section 7430(a).                                                
               Petitioner contends that an “informal survey” of local                 
          attorneys shows that the prevailing hourly rate for attorneys               
          specializing in Federal tax practice in the Seattle, Washington,            
          area is between $225 and $350 and that billing at an hourly rate            
          that is less than the customary rate for similar work is a factor           
          that supports the reasonableness of the attorney’s fees.  With              
          respect to her share of the group fees, petitioner contends that            
          the group fees were charged to a group of Hoyt investor clients,            
          all of whom had pending section 6015 claims, for work relating to           
          common legal and factual issues that directly affected or                   
          contributed to the resolution of each client’s case.                        
          Petitioner’s counsel further contend that the group fee                     
          arrangement allowed the Hoyt investor clients to obtain                     
          professional advice and assistance at a reduced cost, that any              
          services related to the development of factual issues unique to a           
          particular client were charged only to the individual client, and           
          that no client was charged for work that did not directly benefit           
          the client’s case.                                                          







Page:  Previous  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  35  36  37  38  39  Next

Last modified: May 25, 2011