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The problem with petitioner’s attempt to recover her
allocable portion of the general group’s fees and costs is that
the information provided does not enable us to fully evaluate the
reasonableness of the group fees or the reasonableness of the
allocation. The composition of the general group of Hoyt
investors varied from month to month as clients chose to dismiss
their claims or became widowed or divorced and sought relief only
under section 6015(c). Because the billing records for both
petitioner’s and the general group’s accounts lack detailed
information regarding the number of Hoyt investor clients who
participated in the fee arrangement in each of the relevant
months, it is impossible to verify that the generic monthly
charges for group fees that appear on the records for
petitioner’s individual account are reasonable and were
reasonably allocated among petitioner and the other Hoyt
investors clients.23
22(...continued)
those 15 hours, we assume that they were billed at the highest
hourly rate allowed. Further, we do not add any charges for the
15 hours to the total costs and fees incurred by the general
group of Hoyt investors in computing petitioner’s share of that
group’s fees and costs because we lack any information about the
15 hours of work performed.
23Had petitioner produced documentation for each month that
showed the number of clients who shared the fees, such as a
spreadsheet similar to that produced for the January 2004 fee
allocation, we could have properly determined whether the amount
of costs petitioner claims was reasonable.
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