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7430, the section 7430(a) requirement that the costs for such
work are “incurred in connection with” the proceeding would
appear to be satisfied.
Petitioner’s counsel produced billing records for accounts
of two Hoyt investor client groups seeking relief from joint and
several liability to substantiate petitioner’s share of the group
fees. The billing records for both group accounts identify the
attorneys who performed work on the section 6015 cases and set
forth the time expended by each attorney, the attorneys’ hourly
rates, and the nature of the work performed.21 Petitioner’s
counsel contend in their supporting declarations that one group
of Hoyt investors (the general group) ranged in size from 97 to
75 members during the 14-month period that petitioner
participated in the group fee arrangement and that petitioner’s
pro rata share of the general group’s fees was computed by
dividing the total monthly charges equally among all members of
the group. Petitioner’s counsel further contend that there
existed a separate group of nine Hoyt investors, including
petitioner (the litigation group), whose cases were set for trial
during the Court’s February 2004 trial session and that the nine
Hoyt investors shared the total billing costs of trial
preparation equally, with the exception of approximately 15 hours
21The billing records appear to be missing pages for the
month of December 2003, including the summary page of that
month’s total charges. See infra note 24.
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