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SUPPLEMENTAL MEMORANDUM OPINION
BEGHE, Judge: These cases continue before the Court on
petitioners Richard and Fiorella Hongsermeier’s motion under Rule
1612 for reconsideration of our Memorandum Opinion in T.C. Memo.
2006-90 (Dixon VI). Petitioners’ motion arises from litigation
using a test case procedure that resulted in Dixon v.
Commissioner, T.C. Memo. 1991-614 (Dixon II), vacated and
remanded sub nom. DuFresne v. Commissioner, 26 F.3d 105 (9th Cir.
1994), on remand Dixon v. Commissioner, T.C. Memo. 1999-101
(Dixon III), supplemented by T.C. Memo. 2000-116 (Dixon IV),
revd. and remanded 316 F.3d 1041 (9th Cir. 2003) (Dixon V). On
the ensuing remand, Dixon VI responded to the Dixon V primary
mandate with regard to the sanction imposed against respondent;
and Dixon v. Commissioner, T.C. Memo. 2006-97 (Dixon VII), and
Young v. Commissioner, T.C. Memo. 2006-189, responded to the
Dixon V ancillary mandate with regard to petitioners’ appellate
attorney’s fees and costs incurred in Dixon V.
In Dixon V, as a sanction against respondent for the fraud
on the court perpetrated by respondent’s attorneys in the trial
of the test cases that had resulted in the decisions in favor of
respondent against the test case petitioners in Dixon II, the
2Unless otherwise indicated, all Rule references are to the
Tax Court Rules of Practice and Procedure, and all section
references are to the Internal Revenue Code of 1986.
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