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expenses in the amount of $248,049.27 in respect of the PH
petitioners’ appellate fee request.54
IV. Interest
The PH petitioners seek interest on their fee award from
January 17, 2003 (the date of the Court of Appeals’ Dixon V
opinion). As discussed in Part III.B.4.c., supra, the “no-
interest” rule prohibits the recovery of interest in a suit
against the Government absent an express waiver of sovereign
immunity from an award of interest. Library of Congress v. Shaw,
478 U.S. at 311. Section 7430 contains no such express waiver,
see Wilkerson v. United States, 67 F.3d at 120 n.15; Miller v.
Alamo, 992 F.2d at 767; Austin v. Commissioner, T.C. Memo. 1997-
157, and petitioners do not point to any other provision that
might fit the bill. Cf. Miller v. Alamo, supra at 767 (rejecting
the argument that 28 U.S.C. sec. 1961(c)(1) operates as an
express waiver of sovereign immunity from interest on a section
7430 fee award). Accordingly, we deny the PH petitioners’
request for interest on their fee award.55
54 We shall address the manner in which the awards are to be
administered in a separate order or orders implementing this
opinion. In that regard, we note that some nontest case
petitioners who contributed to the Defense Fund during the
relevant period have not been asked to submit net worth
affidavits and therefore have not had the opportunity to
establish their right to share in the awards.
55 We recognize that in Dixon IV we granted postjudgment
interest on petitioners’ sec. 6673(a)(2) fee award. We did so
sua sponte on the basis of “this Court’s inherent power to
protect its own proceedings from abuse, oppression, and
(continued...)
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