STJ Adam B. (“Sport”) Landy touches a subject dear to my heart (and the heart of every one of us in our profession) in Amy E. Grammer, Docket No. 28440-21, filed 2/29/24. Aided by her trusty CPA and fifty-year-veteran trusty attorney, Amy and team got IRS to stip down $123K in deficiencies (two years’ worth) and drop $25K in chops; of course, the stip is unavailable online, but if IRS isn’t fighting Amy’s eligibility for Section 7430 admins and legals, Amy and team must have done enough to warrant a Taishoff “Good Job.”

As for trusty attorney, who retired the end of last year after this triumph, he gets the schedule hourly rate, and better yet, his hours don’t get cut. And they are truly modest, showing the dude knew his stuff and wasn’t running the meter. Amy couldn’t prove either that available legal talent around her homeplace (Dalton, GA) was scarce (a local lawyer testified as to the going hourly rate there for tax controversy work, so STJ Sport concluded there was more than one lawyer working that gig), or that trusty attorney brought different or nontax know-how to the fray.

Trusty CPA gets paid some, but his non-IRS-admitted staff, for whose time he billed, get nothing. Exactly where in Section 7430 admins are limited only to payments to IRS admittees is nowhere stated. Proceedings may take place before the IRS which require extensive preparation and staff work, more efficiently performed by non-admittees.