Estate of John L. Baird, Deceased, Ellen B. Kirkland and J. Samuel Baird, Co-Executors - Page 11

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          Whether Amount of Hours Billed or Costs for Litigation Are                  
          Reasonable in Relation to the Nature of the Issues or the Amount            
          in Controversy?                                                             
               Respondent’s final contention regarding reasonableness of              
          the fees and costs is presented as the generality that the                  
          quantity of hours billed for some of the tasks appears                      
          unreasonable for a single issue (valuation) case.  On this point,           
          respondent does not provide any explanation that would                      
          demonstrate why the amount of hours is excessive and/or the time            
          spent was unnecessary.                                                      
               The estates have provided detailed explanations of the need            
          for the hours incurred and billed to the estates.  The estates              
          also satisfactorily addressed each of respondent’s speculations             
          about the purpose underlying particular costs or fees.                      
               Finally, the estates argue that it was respondent’s                    
          contentious litigating position (holding out for a nominal                  
          discount) that protracted the proceeding and, to some extent,               
          caused increased litigation costs and fees.                                 
               We have reviewed respondent’s general and specific                     
          contentions and the estates’ response and hold that the                     
          estates have adequately shown the claimed costs and fees are                
               Respondent also makes the observation that the amount of               
          fees approaches or approximates the amount of the estate tax                
          deficiencies in the notices of deficiency.  We note, however,               

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Last modified: May 25, 2011