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should not be imposed on him pursuant to section 6673(a)(1), and
we ordered Mr. Jones and Ms. Lacorte to show cause why, in each
case, excess costs should not be imposed on them pursuant to
section 6673(a)(2). We also ordered respondent to inform the
Court of his fees and costs incurred in these cases and of his
positions with respect to the penalties and costs at issue. We
explained to the parties and to counsel that our orders to show
cause were motivated by our concern that petitioners had raised,
and their counsel had abetted them in raising, meritless
arguments that had served merely to delay the collection of taxes
owing. In addition to ordering petitioners and their counsel to
respond in writing to our orders to show cause, we accorded each
the opportunity to appear and be heard. Finally, in the face of
the stipulations of settlement, we vacated the orders we had
entered granting, in whole or in part, respondent’s motions for
summary judgment.
1997 and 1998 Tax Liabilities
On March 5, 2001, respondent issued to Mr. Davis and
petitioner Laura K. Davis (Ms. Davis) a notice of deficiency with
respect to their joint 1997 and 1998 Federal income taxes. Mr.
Davis timely filed a petition in this Court for a redetermination
of the deficiencies; Ms. Davis did not file a petition. On
February 11, 2003, we entered an order and decision in Mr.
Davis’s case, sustaining the deficiencies in full and imposing a
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