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Spaid and the Court. The conference call dealt solely with
frivolous issues raised by Ms. Spaid. We order Ms. Spaid to
reimburse respondent for 2 hours of Ms. Zusi’s time. We do not
order Ms. Spaid to reimburse respondent for Ms. Moe’s time.
On August 1, 2001, Ms. Zusi and Ms. Moe participated in a
conference call with the Court and Ms. Spaid. The conference
call concerned the second stipulation of facts and the
accompanying exhibits. Respondent requests reimbursement for 4
hours of Ms. Zusi’s time and 2 hours of Ms. Moe’s time. We do
not order Ms. Spaid to reimburse respondent for any of the time
spent by Ms. Zusi and Ms. Moe preparing for and participating in
the conference call because it was required by Ms. Spaid’s
negligence.
On August 16, 2001, Ms. Spaid faxed Ms. Zusi a warning that
Ms. Spaid would move for sanctions against the IRS under section
6673(a)(1), which does not provide for sanctions against the IRS.
Ms. Zusi spent 5 hours researching and preparing a defense to the
threatened sanctions. We order Ms. Spaid to reimburse respondent
for 5 hours of Ms. Zusi’s time.
On August 21, 2001, the trial was concluded. Approximately
5 hours of the trial were devoted to frivolous issues, including
the sham trusts and the “Delpit” and “Scar” issues. Ms. Zusi and
Ms. Moe both appeared on behalf of respondent. We order Ms.
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