Laura K. Davis, et al. - Page 19

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          6673(a)(2), but each preferred to respond to our orders in                  
          I.  Introduction                                                            
               Section 6673(a) provides for the imposition of sanctions and           
          the award of costs in Tax Court proceedings.  In pertinent part,            
          the provision provides:                                                     
               SEC. 6673.  SANCTIONS AND COSTS AWARDED BY COURTS.                     
                    (a)  Tax Court Proceedings.--                                     
                           (1) Procedures instituted primarily for                    
                    delay, etc.–-Whenever it appears to the Tax Court                 
                              (A) proceedings before it have been                     
                           instituted or maintained by the taxpayer                   
                           primarily for delay,                                       
                              (B) the taxpayer’s position in such                     
                           proceeding is frivolous or groundless, or                  
                              (C) the taxpayer unreasonably                           
                           failed to pursue available                                 
                           administrative remedies,                                   
                    the Tax Court, in its decision, may require the                   
                    taxpayer to pay to the United States a penalty not                
                    in excess of $25,000.                                             
                           (2) Counsel’s liability for excessive                      
                    costs.–-Whenever it appears to the Tax Court that                 
                    any attorney or other person admitted to practice                 
                    before the Tax Court has multiplied the                           
                    proceedings in any case unreasonably and                          
                    vexatiously, the Tax Court may require--                          
                              (A) that such attorney or other person                  
                           pay personally the excess costs, expenses,                 
                           and attorney’s fees reasonably incurred                    
                           because of such conduct * * *                              

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