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session), we ordered petitioners in each case to show cause in
writing why a penalty should not be imposed on them 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 (1) fees and costs incurred in these
cases and (2) 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 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 counsel to respond in writing to our orders to show cause, we
accorded each the opportunity to appear and be heard.
Tax Liabilities
On April 13, 2001, respondent issued to petitioners Robert
and Ines M. Gillespie (the Gillespies) a notice of deficiency
with respect to their joint 1996 through 1998 Federal income
taxes, and, on May 9, 2003, respondent issued to them a notice of
deficiency with respect to their 1999 Federal income tax. On
April 13, 2001, respondent issued to petitioner Robert E.
Gillespie Asset Management Trust, Robert E. Gillespie, trustee
(the trust and the trustee, respectively), a notice of deficiency
with respect to the trust’s 1996 through 1998 Federal income
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