Laura K. Davis, et al. - Page 4

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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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