Jerry and Patricia A. Dixon - Page 8




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               Mr. Jones filed a supplement and an additional supplement in           
          response to the Court's orders.  Specifically, Mr. Jones executed           
          an affidavit stating that he generally charges his clients $200             
          per hour for his services and $80 per hour for paralegal services           
          and estimating that he and his paralegal expended approximately             
          4,500 hours on behalf of his clients (a group of 43 nontest case            
          petitioners) since June 10, 1992.  Mr. Jones purportedly                    
          increased the charges to his clients relative to the amount of              
          taxes they had in dispute.  Mr. Jones provided the Court with a             
          schedule listing (by amount and date paid) the attorney's fees              
          and costs incurred between June 10, 1992 and August 15, 1999, by            
          the four nontest case petitioners on whose behalf he filed his              
          appearance in the evidentiary hearing, as well as the 39 other              
          nontest case petitioner-participants in Kersting tax shelter                
          programs.  The schedule indicates that the Alversons, Baughmans,            
          Cerasolis, and McComases paid attorney's fees and costs totaling            
          $13,875, $12,450, $11,567, and $13,100, respectively, during the            
          period in question.                                                         
          In a supplement to his motions, Mr. Izen stated that he had                 
          charged his clients $150 per hour and that he had received                  
          attorney's fees totaling $743,464.49 during the period June 1992            
          to September 1999.  Mr. Izen further stated that petitioners had            
          incurred total attorney's fees of $1,196,706.19 during the period           
          in question and that such fees had been paid to a number of                 






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