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motion was filed approximately 92 days after the petition.
We agree with respondent that this was reasonable. Cf.
Harrison v. Commissioner, 854 F.2d 263 (7th Cir. 1988),
affg. T.C. Memo. 1987-52 (concession some 6 months after
answer filed, after respondent had an opportunity to verify
information, held reasonable); Wickert v. Commissioner, 842
F.2d 1005 (8th Cir. 1988), affg. T.C. Memo. 1986-277
(concession 10 days after filing of answer, although it
took several months to draft the stipulation of settlement,
held reasonable); Ashburn v. United States, 740 F.2d 843
(11th Cir. 1984) (11-month delay in conceding case not
unreasonable); White v. United States, 740 F.2d 836, 842
(11th Cir. 1984) (Government's concession of issue 3 months
after issue raised held reasonable); Sokol v. Commissioner,
92 T.C. 760 (1989); Goertler v. Commissioner, supra
(Commissioner’s concession approximately 90 days after
receiving documentation sufficient to substantiate the
deduction in question held reasonable); St. John v. United
States, 84 AFTR 2d 99-5867 (W.D. Mich. 1999) (an award of
attorney’s fees not warranted where the Government conceded
the issues in Count I of a refund suit “within a relatively
short period after being served with the complaint, and
prior to answering it” and the taxpayer conceded the issues
in Count II, but months passed before the concessions were
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