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that were allocated among the general group. In addition,
petitioner’s counsel produced a spreadsheet demonstrating how the
total monthly fees incurred by the general group of Hoyt investor
clients in January 2004 were divided equally among petitioner and
the other participants.
After reviewing the record, we conclude that petitioner’s
share of the group fees was incurred in connection with her
section 6015 proceeding, that petitioner has benefited from the
work her attorneys performed for both groups of Hoyt investor
clients, and that petitioner is entitled to recover a reasonable
share of the fees and costs she incurred as a member of each
group. With respect to the litigation group of Hoyt investor
clients, we award petitioner $3,577.22, which represents a one-
ninth share of the attorney’s fees adjusted to an hourly rate of
$150 and costs.22
22We compute petitioner’s share of the litigation group’s
fees and costs as follows: $37,667 (total fees and costs
incurred by litigation group), minus $13,962 (work performed by
attorneys at $195 hourly rate), plus $10,740 (total attorney’s
fees incurred at $195 hourly rate adjusted to hourly rate of
$150), minus $2,250 (15 hours of work performed at an hourly rate
of $150), divided by 9 (members of litigation group), equals
$3,577.22.
We subtracted 15 hours of work performed at an hourly rate
of $150 in computing the total amount of fees and costs incurred
by the litigation group because petitioner’s counsel stated that
approximately 15 billable hours shown on the billing records of
the litigation group’s account were actually charged to the
members of the general group. Because petitioner’s counsel have
failed to identify the nature of the work or hourly rate for
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