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
Nancy J. Johnson Bayer, Petitioner v. Commissioner of Internal Revenue, Respondent
Bayer v. Commissioner
Docket No. 11408-89
United States Tax Court
98 T.C. 19; 1992 U.S. Tax Ct. LEXIS 3; 98 T.C. No. 2;
January 9, 1992, Filed
An appropriate order will be issued.
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…
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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