- 7 - sanction resting in the discretion of the trial court. Levy v. Commissioner, 87 T.C. 794, 803 (1986). As set forth above, petitioners failed to cooperate with respondent in her attempt to either reach a settlement in the case or to prepare properly for trial. Petitioners delayed the proceedings under the pretext of wanting to amicably settle this case. Petitioners' bad faith, coupled with their failure to cooperate, has made it impossible for respondent to conduct negotiations or otherwise proceed with this case. Accordingly, we grant respondent's motion to dismiss for failure to properly prosecute. Therefore, respondent prevails on the underlying deficiencies and the additions to tax. Decision will be entered for Respondent.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011