- 2 -
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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