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below, in which respondent sets forth the considerable resources
expended in the case at hand. Additionally, we have taken into
account petitioner’s conduct throughout the administrative
proceedings, in which petitioner was uncooperative and
unreasonable. Petitioner’s “Affidavit in Appellant’s Response to
Sanctioned Pursual”, in which petitioner again succumbed to the
temptation to make frivolous arguments, confirms the necessity of
a substantial penalty. Therefore, on the basis of petitioner’s
misconduct in the administrative and Court proceedings, we shall
impose a penalty of $24,000 under section 6673(a)(1).
Section 6673(a)(2) Liability of Ms. Spaid
Section 6673(a)(2) authorizes the Court to impose costs on
an attorney who has unreasonably and vexatiously multiplied the
proceedings. Section 6673(a)(2) is modeled after section 1927 of
the Judicial Code, 28 U.S.C. sec. 1927 (2000), and the Court has
relied on cases arising under 28 U.S.C. section 1927 to ascertain
the level of misconduct justifying sanctions under section
6673(a)(2). See Takaba v. Commissioner, supra; Harper v.
Commissioner, 99 T.C. 533, 545 (1992).
In Takaba v. Commissioner, supra, we recently observed that
the venue for appeal of sanctions under section 6673(a)(2) may be
the Court of Appeals for the District of Columbia Circuit. See
id. at 297 (citing section 7482(b)(1)). We found that the Court
of Appeals for the District of Columbia Circuit had adopted a
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