- 13 - Based upon the foregoing, we conclude that petitioner has had sufficient experience with this and other courts to know that he would be receiving important mailings pertaining to this case and that he must contact the Court and respondent to give notice of his address change. Instead, petitioner waited until this case was called for trial to allege that he had not received the Court's or respondent's notices. Petitioner then deliberately misstated his legal experience in an apparent attempt to persuade the Court to show leniency by vacating the deemed admissions based upon his assertion that he had not received the Court's or respondent's notices. Had the Court known the extent of petitioner's legal experience at the time of the call of this case from the calendar, the Court would have held petitioner to the deemed admissions when he appeared at that time. A continuance and hearing would not have been necessary. In short, by deliberately misstating his experience before this Court, petitioner abused the Court's processes and caused undue delay. Petitioner's unacceptable conduct in the instant case resulted in an unnecessary and considerable waste of the Court's time and resources. Accordingly, the maximum penalty is appropriate, and we therefore, on our own motion, require petitioner to pay to the United States a penalty in the amount of $25,000. See sec. 6673(a)(1).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011