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possible to multiply, or prolong, the proceedings after a case
has been initiated; presumably because an attorney cannot begin
to multiply the proceedings until some proceeding has come into
existence for the attorney to multiply. Compare Moore v. Keegan
Mgmt. Co., 78 F.3d 431, 435 (9th Cir. 1996) (28 U.S.C. sec. 1927
“applies only to unnecessary filings and tactics once a lawsuit
has begun”), with In re TCI Ltd., 769 F.2d 441, 448 (7th Cir.
1985) (under 28 U.S.C. sec. 1927, trial judge “had the authority
to award the fees incurred right from the beginning”). We have
not addressed the analogous issue under section 6673(a)(2), and
we are not compelled to do so today since, with respect to
respondent’s costs incurred in responding to the first pleadings
(i.e., answering the petitions), there is adequate basis under
Rule 33(b) for imposing upon Mr. Jones respondent’s reasonable
expenses, including reasonable counsel’s fees, incurred in
answering those pleadings.
The text of Rule 33(b) is set forth supra. By signing a
pleading, the signer certifies, among other things, that, after a
reasonable inquiry, he has concluded that, to the best of his
knowledge, the pleading is well grounded in fact and law. The
signer must inquire into both the facts and the law at the time
the pleading is filed. Versteeg v. Commissioner, 91 T.C. 339,
342 (1988). Mr. Jones does not argue that he made a reasonable
inquiry that led to his erroneous conclusion that petitioners’
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