a "Partner”). PI. Reply. Ex. A. at 1. 23 . The court has deducted the 53.6 hours in 2012, th.e 13.4 hours in 2013, the 7.1 hours in 2014, and the 0.5 hours in 2015 that Sutherland Asbill spent in connection with proceedings before the IRS or the United States Tax Court. Pi. Reply Ex. E. In addition, the court has deducted an additional .2 hours in 2015 and .1 hours in 2016 that the court determined was spent in connection with United States Tax Court proceedings upon review of Plaintiff’s Exhibits. PI. Mem. Ex. D at 26 (12/2/2015 entry for .2 hours for "Attention to multiple Tax Court notices; email to clients"); PL Mem Ex. D at 27 (2/11/2016 entry for .1 hours for "Attention to Tax Court orders on CDP cases"). See Oliveira v. United States, 827 F.2d 735, 744 (Fed. Cir. 1987) (<HOLDING>). 24 . For 2012, 2013, 2014, 2015, and 2016,
holding that pursuant to the eaja courts may not award expenses of an attorney that are not incurred or expended solely or exclusively in connection with the case before the court holding that under the eaja a prevailing party with an unconditional right to be indemnified for his legal expenses by a solvent third party had not incurred attorneys fees holding that an award for medical expenses is proper when the expenses have been incurred but not paid holding attorney fees may be allowed for expenses incurred for default holding that attorney fees are incurred only when there is an express or implied agreement that the fee award will be paid over to the legal representative