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raised or maintained by Ms. Spaid that vexatiously multiplied the
proceedings. On the basis of Ms. Zusi’s and Ms. Moe’s years of
experience and the location of their office, respondent requested
a rate of $200 per hour for Ms. Zusi and Ms. Moe. Applying this
multiplier, respondent requested a total of $40,200 in attorney’s
fees.
Ms. Spaid filed an “Opposition to Affidavit in Support of
Attorney’s Fees for Sanctions”. Ms. Spaid’s submission objects
to the imposition of section 6673(a)(2) costs against her but
does not object to the imposition of a penalty against petitioner
under section 6673(a)(1). Ms. Spaid contends the “Agency”,
“Delpit”, and “Scar” issues were appropriate lines of inquiry.
With respect to the abusive trust issue, Ms. Spaid contends the
abusive trusts are not a sanctionable area. Ms. Spaid also takes
issue with respondent’s itemization of time spent on each
particular frivolous issue. Although Ms. Spaid did not file a
motion for reconsideration, the objection concludes with a
request for the Court to reconsider our position with respect to
section 6673(a)(2).
Petitioner filed an “Affidavit in Appellant’s Response to
Sanctioned Pursual” (sic). Petitioner’s submission repeats many
of the arguments we found to be frivolous in our opinion in
Edwards v. Commissioner, supra, and also repeats Ms. Spaid’s
prior request that the Court impose sanctions on respondent.
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