- 33 -
claims had merit. Indeed, we have concluded that he signed the
petitions knowing that they lacked merit. Mr. Jones signed the
petitions in violation of Rule 33(b) and is deserving of a
sanction on account thereof.
5. Excess Costs
Attorney's fees awarded under section 6673(a)(2) are to be
computed by multiplying the number of excess hours reasonably
expended on the litigation by a reasonable hourly rate. Takaba
v. Commissioner, 119 T.C. at 303. The product is known as the
“lodestar” amount. Id. To assist us in computing the lodestar
amount, respondent has provided us with the declarations of
attorneys Alan J. Tomsic, Wesley J. Wong, and Paul C. Feinberg
(Messrs. Tomsic, Wong, and Feinberg, respectively, and the
Tomsic, Wong, and Feinberg declarations, respectively). Attached
to the Tomsic and Wong declarations are copies of reports
generated from respondent’s internal time keeping records showing
the number of hours expended on these cases by Messrs. Tomsic and
Wong. Although the Feinberg declaration includes the number of
hours he expended on these cases, he does not provide reports
similar to those provided by Messrs. Tomsic and Wong, declaring
that he does not keep detailed records by individual case number
for time he spends in a supervisory capacity. Messrs. Tomsic and
Wong, explicitly, and Mr. Feinberg, by inference, calculate their
time expended working on these cases from their first contacts
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