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B. Costs Pursuant to Section 6673(a)(2)
1. Introduction
Ms. Sluyter has been ordered to show cause why she should
not be required to pay costs pursuant to section 6673(a)(2) (the
order to show cause or the order). She has not obeyed the order.
Respondent has filed his memorandum of points and authorities in
support of the order (respondent’s memorandum), along with the
declaration of Paul K. Webb, Esq. (the Webb declaration). For
the reasons that follow, we shall make the order to show cause
absolute.
2. Section 6673(a)(2)
Section 6673(a)(2) provides for counsel’s liability for
excessive costs. In pertinent part, section 6673(a)(2) provides:
Counsel’s liability for excessive costs. Whenever it
appears to the Tax Court that any attorney or other
person admitted to practice before the Tax Court has
multiplied the proceedings in any case unreasonably and
vexatiously, the Tax Court may require--
(A) that such attorney or other person pay
personally the excess costs, expenses, and
attorneys’ fees reasonably incurred because
of such conduct * * *
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