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preparation, appearing at the calendar call and trial as counsel,
and preparing both respondent’s opening and reply briefs.
Respondent also asks for reimbursement of 34 hours of Ms.
Moe’s time at $200 an hour. Ms. Moe is an associate area counsel
in respondent’s San Jose, California, Office of Chief Counsel and
is Ms. Zusi’s supervisor. Ms. Moe has been with the Office of
Chief Counsel since 1984. The total attorney’s fees requested by
respondent for Ms. Zusi and Ms. Moe amount to $40,200.
On October 24, 2002, Ms. Spaid filed an “Opposition to
Affidavit in Support of Attorney’s Fees for Sanctions”. Ms.
Spaid’s submission objects to the imposition of section
6673(a)(2) costs against her but does not object to imposition of
the section 6673(a)(1) penalty against petitioner. Ms. Spaid
contends the “Agency”, “Delpit”, and “Scar” issues were
appropriate lines of inquiry. With respect to the “Delpit”
issue, Ms. Spaid’s objection declares she “felt it was time for
the court to look at the purpose of the administrative procedures
* * * thus changing the law in favor of the taxpayer.” The
objection states that the “Agency” issue was raised only in
“paperwork” and was never responded to by respondent. The
objection says that the “Scar” issue was raised because the
notice of deficiency had not allowed any deductions for
petitioner and that seemed “unfair on the face of it”. With
respect to the abusive trust issue, Ms. Spaid claims the abusive
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