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Commissioner, 99 T.C. at 549. Respondent has submitted
respondent’s memorandum in support of the order to show cause.
In support of respondent’s memorandum, respondent has submitted
the Webb declaration (declaration of Paul K. Webb, respondent’s
counsel). Attached to the Webb declaration are copies of
respondent’s internal time keeping records, reflecting the total
time expended on the consolidated cases by, among others,
attorneys Paul K. Webb, Dale A. Zusi, and Debra K. Moe. Their
total time spent working on the cases is set forth, as well as
their time spent working on the cases since the appearance of Ms.
Sluyter. Since the appearance of Ms. Sluyter, the hours spent
working on the cases by Mr. Webb, Ms. Zusi, and Ms. Moe are
202.75, 17.25, and 13.5, respectively. Respondent asks
reimbursement only for those hours spent by his attorneys on
tasks that would not have been required in the absence of
Ms. Sluyter’s “vexatious actions multiplying these proceedings”
(excess hours).
Respondent asks reimbursement for 56.75 hours of Mr. Webb’s
time, at a rate of $125 an hour. Mr. Webb is the attorney with
day-to-day responsibility for the cases. He is an attorney
employed in respondent’s San Jose, California, District Counsel’s
office. He has been a member of the California State Bar since
1987. He has detailed the time he spent on the cases, which
involved time spent on research, drafting, review of submissions
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