Jerry and Patricia A. Dixon - Page 12




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          these cases:  (1) Messrs. Izen, Jones, and Sticht failed to                 
          substantiate the nature of the services rendered and the amount             
          of attorney's fees that their clients incurred as a consequence             
          of the Government misconduct; and (2) the Court has already                 
          imposed significant sanctions on respondent in Dixon III.9                  
               The Court subsequently directed respondent to file a                   
          supplement to respondent's objection including (1) a detailed               
          statement, for each taxable year in issue, of the elements and              
          methodology of respondent's computation of the reduction in                 
          petitioners' liability associated with the sanctions that the               
          Court imposed in Dixon III, and (2) a detailed computation of               
          petitioners' liability for interest under sections 6601(a) and              
          6621(a) for the years before the Court for the period June 10,              
          1992 (the date the Court filed respondent's motions to vacate the           
          decisions in the Thompson and Cravens cases) through March 30,              
          1999 (the date the Court issued its opinion in Dixon III).                  
          Respondent complied with the Court's order.                                 
               Respondent filed a further supplement to respondent's                  
          objection to the motions of Messrs. Izen and Jones, specifically            
          challenging the adequacy of the supplemental materials that they            
          filed.  With regard to the materials submitted by Mr. Izen,                 
          respondent argued that the fees paid by the Belton fund to Mr.              



          9  Respondent's objections included an addendum quantifying                 
          the impact of the sanctions that the Court imposed in Dixon III.            





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