Laura K. Davis, et al. - Page 2

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               unreasonably failing to pursue available administrative                
                    2.  Held, further, Ps’ lead counsel liable for R’s                
               attorney’s fees since he signed pleadings and other                    
               papers knowing Ps’ claims to be meritless and, thus,                   
               abused the judicial process and unreasonably and                       
               vexatiously multiplied the proceedings.                                

               Robert Alan Jones, Maria Angelisa L. Lacorte, and Mario P.             
          Fenu, for petitioners.                                                      
               Alan J. Tomsic and Paul C. Feinberg, for respondent.                   

                                 MEMORANDUM OPINION                                   

               HALPERN, Judge:  Each of the cases in this consolidated                
          proceeding is before the Court to determine whether the                     
          petitioner therein must pay a penalty pursuant to section                   
          6673(a)(1) and whether two of petitioners’ counsel common to all            
          of the cases, Robert Alan Jones (Mr. Jones) and Maria Angelisa L.           
          Lacorte (Ms. Lacorte), must pay certain of respondent’s costs               
          pursuant to section 6673(a)(2).  For the reasons that follow, we            
          impose on petitioner Jeffrey W. Davis (Mr. Davis) penalties                 
          totaling $15,000 and on Mr. Jones costs totaling $25,800.                   
               Unless otherwise indicated, all section references are to              
          the Internal Revenue Code of 1986, as amended, and all Rule                 
          references are to the Tax Court Rules of Practice and Procedure.            
               Generally, we shall use the term “counsel” to refer to Mr.             
          Jones and Ms. Lacorte.                                                      

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