- 66 - fees on a pro rata basis. Again, we are not aware of any authority requiring us to do so, and we think such an approach would run counter to the remedial purpose of section 7430. Accordingly, we allocate the eligible contributions first to the Defense Fund’s $122,293.30 payment for potentially compensable fees. It follows that eligible persons paid all of those potentially compensable fees. b. Porter & Hedges Agreement We take a similar approach with regard to the $60,000 the Defense Fund paid to Porter & Hedges. Of the $514,821.90 claimed by the PH petitioners in their appellate fee request, $248,049.27 is potentially compensable. See supra Parts III.D.3., III.E. First, we allocate the entire $60,000 expenditure to the potentially compensable fees and expenses. Next, we identify the contributions to the Defense Fund from which the Fund’s $60,000 expenditure derived. We believe it is reasonable to treat the $60,000 expenditure as having derived from the $84,200 contributed to the Defense Fund by the Dixons and the group of 43 from December 2001 through April 2002. The following table lists the persons described in the preceding paragraph (i.e., the Dixons and the group of 43) for whom we have received net worth affidavits, together with the amount contributed by each such person to the Defense Fund during the relevant period:Page: Previous 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 Next
Last modified: May 25, 2011