Jerry and Patricia A. Dixon - Page 6



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          acts of Government misconduct, the Court exercised its inherent             
          power and imposed sanctions against respondent.  In particular,             
          the Court held that Kersting program participants who either had            
          not had decisions entered in their cases or whose decisions were            
          not final were relieved of liability for (1) the interest                   
          component of the addition to tax for negligence under sections              
          6653(a)(2) and 6653(a)(1)(B), and (2) interest computed at the              
          increased rate prescribed in section 6621(c).                               
               Motions of Messrs. Izen and Jones                                      
               On June 24, 1999, Messrs. Izen and Jones filed motions with            
          supporting memoranda for attorney's fees and costs and for                  
          sanctions on behalf of test case and nontest case petitioners.              
          Relying on 5 U.S.C. section 504 (1994), 28 U.S.C. section 2412              
          (1994), and sections 7430 and 6673(a)(2)(B), Messrs. Izen and               
          Jones asked the Court for an award of attorney's fees and costs             
          to their clients.  Relying on Fed. R. Civ. P. 11, Tax Court Rule            
          230, and section 6673(a)(2)(B), Messrs. Izen and Jones also                 
          contended that the Court should impose sanctions against                    
          respondent in an amount not less than $2 million.  Messrs. Izen             
          and Jones requested the Court to order respondent to pay any such           
          award and sanctions to petitioners immediately, rather than                 
          waiting for assessment and collection of the underlying                     
          deficiencies under section 6213(a).                                         
          Because the decisions in the test cases had not become final                
          by the time that Messrs. Izen and Jones filed their motions, the            





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