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unreasonably failing to pursue available administrative
remedies.
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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