- 30 -                                        
          Conduct (Part Two)”, 56 La. L. Rev. 1, 119 (1995).  While it is             
          often difficult to allocate attorney time between successful and            
          unsuccessful issues and claims, “denial of a particular form or             
          aspect of relief occasionally may be attributable to a discrete             
          motion or proceeding, thus allowing the limited success factor to           
          be measured by hours devoted to that effort.”  Id.; see also                
          Hensley v. Eckerhart, supra at 436 (a court applying these                  
          principles “may attempt to identify specific hours that should be           
          eliminated”).                                                               
                    b.   Hours Relating to the Issue of Attorney’s Fees               
               Respondent does not dispute that hours devoted to the                  
          recovery of attorney’s fees (sometimes referred to herein as “fee           
          request” hours) are potentially compensable under section 7430.             
          See, e.g., Huffman v. Commissioner, 978 F.2d 1139, 1149 (9th Cir.           
          1992), affg. in part and revg. in part on other grounds T.C.                
          Memo. 1991-144.  The fees generated by fee request hours are                
          commonly referred to as “fees-on-fees” or “fees-for-fees” (as               
          opposed to “merits” fees, which are attributable to “merits”                
          hours).  Because we apply a separate percentage reduction to the            
          portion of Izen’s lodestar attributable to fee request hours (the           
          fees-on-fees lodestar) based on the ratio of merits hours allowed           
          to merits hours claimed, see infra Part III.F., we separately               
          identify his merits hours and fee request hours.20                          
          20 The Jones fee request (as supplemented) does not include                 
                                                              (continued...)          
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