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Petitioner asks the Court to use its inherent power and
authority to regulate and supervise proceedings before it so as
to insure the integrity of its processes. See Freytag v.
Commissioner, 501 U.S. 868, 891 (1991); Chambers v. NASC0, Inc.,
501 U.S. 32, 43-46 (1991). The Court’s inherent power extends to
regulate both conduct before it and conduct beyond its confines.
See Chambers v. NASCO, Inc., supra at 44. The Court has
recognized its authority to maintain the integrity of its
proceedings and its ability to provide relief for a party’s
misconduct. See, e.g., Dixon v. Commissioner, T.C. Memo. 2000-
116 (imposing additional sanctions, some on the basis of inherent
power); Dixon v. Commissioner, T.C. Memo. 1999-101; CMEM, Inc. v.
Commissioner, T.C. Memo. 1991-467.
V. Burden of Proof
Petitioner has the burden of establishing the allegations of
illegal and improper acts by respondent that are the basis of the
motion. See Rakas v. Illinois, 439 U.S. 128, 130 n.1 (1978)
(citing Simmons v. United States, 390 U.S. 377, 389-390 (1968)
(“The proponent of a motion to suppress has the burden of
establishing that his own Fourth Amendment rights were violated
by the challenged search or seizure.”)).
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