Jerry and Patricia A. Dixon, et al. - Page 66

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          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:                                                        






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