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motion should be denied on the ground that the Court imposed
substantial sanctions against respondent in Dixon III.
Mr. Izen's most recent supplement to his motions included a
request for a further extension of time to provide additional
materials to the Court. Upon receipt of respondent's objection
to his motion for sanctions, Mr. Sticht filed a motion seeking
permission to file a reply. Considering the delays associated
with petitioners' current motions and counsels' repeated failures
to produce the documentation needed to substantiate fully their
clients' claims, the Court has concluded that further extensions
are unwarranted.
Discussion
I. Attorney's Fees and Costs
Messrs. Izen and Jones jointly filed motions for attorney's
fees and costs relying primarily on sections 7430 and 6673. Mr.
Sticht likewise seeks, among other sanctions, an award of
attorney's fees and costs. Mr. Sticht asserts that the Court
should rely on its inherent power in imposing such sanctions.
A. Section 7430
Section 7430, enacted under the Tax Equity and Fiscal
Responsibility Act of 1982 (TEFRA), Pub. L. 97-248, sec. 292(a),
96 Stat. 324, 572, provides that certain prevailing parties are
entitled to recover reasonable litigation costs from the United
States in specified civil tax cases. As originally enacted,
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