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agree, however, with the principal argument made by respondent in
the motions to quash: viz., the testimony of the subpoenaed
witnesses is irrelevant to the Court’s redetermination of the
deficiencies determined by respondent. The statement in the
response to the motions to quash that the issue before the Court
is whether the IRS and the U.S. Government “have legitimate
authority over the lives and property of the petitioners” is, as
we have discussed, groundless, and served only to unreasonably
protract these proceedings. Moreover, the response contains the
unsupported (and unsupportable) charge that respondent’s counsel
lied about Zimmerman v. United States, supra. The response also
claims, without support: “Each witness has initiated force
against the petitioners.” Such charges can only have been made
to vex or distress respondent, his counsel, and this Court.
From the time Ms. Sluyter entered her appearances in these
cases to the present, she has acted to multiply these proceedings
by actions that are both unreasonable and vexatious. There
remains only the question of the amount of costs we shall require
her to pay.
4. Costs
“Attorney’s fees awarded under section 6673(a)(2) are to be
computed by multiplying the number of excess hours reasonably
expended on the litigation by a reasonable hourly rate. The
product is known as the ‘lodestar’ amount.” Harper v.
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