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claimed.” Rule 231(d); see also Cassuto v. Commissioner, 93 T.C.
256, 271 (1989), affd. in part, revd. in part on other grounds
and remanded 936 F.2d 736 (2d Cir. 1991). Petitioners’ affidavit
does not describe the specific nature of the work performed by
their attorney, the number of hours their attorney worked on each
matter, or the date such work was performed. Accordingly,
petitioners are not entitled to recover administrative and
litigation costs. Rule 231(d).
Contentions we have not addressed are irrelevant, moot, or
meritless.
To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011