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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
reasonable.
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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