testamentary trust for the estate.
On July 8, 1976, the applicant tried the testamentary trust case before the bankruptcy court in a two and one-half hour trial. During this short trial, several attorneys represented interests adverse to the estate for little or no compensation. The estate prevailed at the trial and was awarded certain interests in the bankrupt's testamentary trust. On appeal, the applicant successfully defended the trial court decision by brief in the district court and by brief and oral argument in the Sixth Circuit Court of Appeals.
After the trust issue was resolved, the applicant engaged in an accounting to determine whether or not the estate had received the funds to which it was entitled. This accounting was also necessary so the estate could respond to tax claimsfor fees in the amount of $33,750.00 is excessive.
The applicant testified at trial that confusion existed as to which office of the IRS had the authority to resolve this particular tax dispute. Instead of placing the tax dispute in a posture from which the estate could litigate the claim in the bankruptcy court, the applicant involved the estate in lengthy discussions with various departments of the IRS. The confusion over the proper administrative office to handle settlement discussions with the estate resulted in the estate engaging in the same or similar settlement discussions on at least two separate occasions. A settlement was reached with the appellate division of the IRS regional commissioner's office only to have that settlement questioned by the IRS *333 district counsel's office. The applicant