Bayer v. Commissioner
United States Tax Court
R filed a motion for reconsideration of our opinion, T.C. Memo. 1991-282, filed June 24, 1991, in which we concluded that P was entitled to reimbursement for her reasonable administrative and litigation costs under sec. 7430, I.R.C.Sec. 7430(c)(1)(B)(iii) limits the hourly rate for reimbursement of attorney's fees to $ 75 "unless the court determines that an increase in the cost of living or a special factor" justifies a higher rate.
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R filed a motion for reconsideration of our opinion, T.C. Memo. 1991-282, filed June 24, 1991, in which we concluded that P was entitled to reimbursement for her reasonable administrative and litigation costs under sec. 7430, I.R.C.Sec. 7430(c)(1)(B)(iii) limits the hourly rate for reimbursement of attorney's fees to $ 75 "unless the court determines that an increase in the cost of living or a special factor" justifies a higher rate. In our prior opinion, filed June 24, 1991, which followed the opinion of this Court in Cassuto v. Commissioner,93 T.C. 256 (1989) affd. in part, revd. and…
1Opinion of the Court
SUPPLEMENTAL OPINION
DRENNEN, Judge:
This matter is before the Court on respondent's motion for reconsideration of our opinion, T.C. Memo. 1991-282, pursuant to Rule 161.1 In that opinion, filed June 24, 1991, we concluded, inter alia, that petitioner was entitled to an award of attorney's fees and litigation costs under section 7430. By order, dated June 27,1991, the parties were directed to submit a computation of the attorney's fees and costs to which petitioner was entitled under section 7430.
Section 7430(c)(l)(B)(iii) limits the hourly rate for attorney's fees to $75, with allowances for…
2Cases cited18 opinions
- Jack E. Golsen and Sylvia H. Golsen v. Commissioner of Internal RevenueCourt of Appeals for the Tenth Circuit · 1971
- Mary Jane Ruderman Hirschey v. Federal Energy Regulatory Commission, Long Lake Energy Corporation, IntervenorCourt of Appeals for the D.C. Circuit · 1985
- Richard J. Todd and Denese W. Todd v. Commissioner of Internal RevenueCourt of Appeals for the Fifth Circuit · 1988
- Federal Power Commission v. Memphis Light, Gas & Water DivisionSupreme Court of the United States · 1973
- Joseph Trichilo v. Secretary of Health and Human ServicesCourt of Appeals for the Second Circuit · 1987
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