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responsible for respondent’s costs reasonably incurred as a
result of having to prepare to defend against all her frivolous
arguments. However, we will not include any of the time spent
by respondent in considering Ms. Spaid’s frivolous arguments in
preparing respondent’s posttrial briefs, which properly made no
more than a passing reference to the lack of content of those
arguments. The time spent appears excessive and did not result
in any legal work product that was helpful to the Court.
In our opinion in Edwards v. Commissioner, supra, we decided
we would award respondent costs under section 6673(a)(2) for Ms.
Spaid’s knowing and reckless advocacy of frivolous issues. In
addition to her sanctionable conduct, Ms. Spaid exhibited a large
measure of disorganization and negligence in performing routine
litigation matters. We will not award respondent’s costs for the
time spent by Ms. Zusi and Ms. Moe that was directly attributable
to responding to Ms. Spaid’s disorganization and negligence. We
will reduce the fees requested by respondent to an amount that we
estimate is more commensurate with the time spent by Ms. Zusi and
Ms. Moe in responding to the frivolous arguments without regard
to the disorganized and negligent fashion in which Ms. Spaid
prepared for trial, including the time spent on discovery and
preparation of the second stipulation of facts, which was
primarily designed to provide support for Ms. Spaid’s frivolous
arguments. After considering respondent’s affidavit and Ms.
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