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claimed services were in connection with this court proceeding.
Before we address these issues, we are asked to decide whether
petitioner has provided a detailed affidavit that distinctly sets
forth each item or cost paid or incurred for which an award is
claimed. See Cassuto v. Commissioner, 93 T.C. 256, 271 (1989),
affd. in part and revd. in part on other grounds 936 F.2d 736 (2d
Cir. 1991).
1. Petitioner’s Affidavit
Rule 232(d) provides that if the parties are unable to agree
as to the amount of attorney’s fees that is reasonable, the
moving party shall file an additional affidavit which includes:
(1) A detailed summary of the time expended by each individual
for whom fees are sought, including a description of the nature
of the services performed during each period; (2) a description
of the fee arrangement; (3) the professional qualifications and
experience of each individual for whom fees are sought; (4) a
statement of whether a special factor exists; and (5) any other
relevant information to assist the Court in evaluating the claim
for costs and fees.
Attached to petitioner’s opening brief was a detailed
affidavit of the hours petitioner’s counsel spent in connection
with these proceedings. The affidavit also contained a brief
description of the services provided and the qualifications of
petitioner’s counsel. Respondent has not objected to the
detailed affidavit’s being attached to petitioner’s opening
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