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expense statements identifying the nature of the services that he
provided to his clients. Respondent also asserts that Mr. Jones
failed to bill his clients based upon a coherent fee schedule,
making it difficult to determine the proper amount of an award of
attorney's fees. Finally, respondent directed the Court's
attention to various materials, including one of Mr. Kersting's
so-called Dear Friend letters (dated February 6, 1992), which
suggest that a portion of Mr. Jones' fees relates to advice that
Mr. Jones provided to his clients regarding "asset protection
services"; i.e., bankruptcy advice. Respondent asserts that such
fees were not incurred as a consequence of the Government
misconduct.
Respondent filed a separate objection to Mr. Sticht's
motion. Respondent contends that an award of attorney's fees
under section 6673(a)(2) is not warranted in these cases inasmuch
as the Government misconduct in the trial of the test cases was
not vexatious and the Government exhibited its institutional good
faith by promptly bringing the misconduct to the Court's
attention in June 1992. Respondent also challenged Mr. Sticht's
request for an award of attorney's fees on the ground that Mr.
Sticht, like Messrs. Izen and Jones, failed to provide the Court
with time sheets or expense statements describing his services to
his clients. Finally, respondent asserts that Mr. Sticht's
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