Robert and Ines M. Gillespie, et al. - Page 2




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                    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.                                                      
               Wesley J. Wong and Paul C. Feinberg, for respondent.                   


                                 MEMORANDUM OPINION                                   

               HALPERN, Judge:  The cases in this consolidated proceeding             
          are before the Court to determine whether petitioners must pay              
          penalties 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                      
          petitioners penalties totaling $15,000 and on Mr. Jones costs               
          totaling $12,798.                                                           
               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.            
               For convenience, we shall use the term “petitioners” to                
          refer to all of the petitioners, collectively, and also to refer            
          to the petitioners or the petitioner in each of the cases before            






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