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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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