Robert Jones has just rendered service for a taxpayer as an expert witness in a case heard by the U. S. Tax Court. The taxpayer is requesting reimbursement for Jones' fees and for those amounts paid to her attorney in presenting the case. Jones' billing rate for this type of engagement is $500 per hour, the market rate for such services in his city, plus out- of- pocket expenses (e. g., auto mileage, computer charges). How much of Jones' fee will the taxpayer recover? Prepare in tax research memo format to include relevant facts, specific issues, conclusions, and support sections.