actions against BASR’s partners while the TEFRA proceeding was pending in the United States Court of Federal Claims, and I.R.C § 7430 allows a taxpayer to recover “reasonable litigation costs incurred in connection with such court proceeding.” Pl. Reply at 20 (quoting I.R.C. § 7430(a)(2) (emphasis added)). To the extent that court is inclined to deny that portion of the fee request, it amounts to $21,395. As to the Government’s objection that Sutherland Asbill’s paralegal work was “purely clerical,” a review of the work shows that paralegals organized documents and cite cheeked pleadings and briefs, all of which was work that “if not performed by the paralegal, would have been performed personally by the [plaintiffs] attorneys.” Pl. Reply at 20 (quoting Miller, 983 F.2d at 862 (<HOLDING>)). In addition, the time Sutherland Asbill
holding that the petitioner may not turn a clerical error into a windfall of rights it would not otherwise enjoy internal quotation marks omitted holding that your work exclusion is triggered only where the damage at issue is to work performed by you and is caused by work performed by you  and does not apply to damage caused to original construction of a house during later repair work holding that the evidence was insufficient to support the plaintiffs sexbased hostile work environment claim because even though much of the complainedof conduct was boorish and offensive most of it was not personally experienced by the plaintiff holding presumption applies to analyzing whether injury suffered going to work was compensable because route constituted special hazard holding that paralegal work involving going to a library to locate cases was compensable because it otherwise would be performed personally by the plaintiffs attorneys and was not purely clerical in nature