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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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