- 29 -
The Court has inherent power to protect its own proceedings
from abuse, oppression, and injustice. See Fu Inv. Co. v.
Commissioner, 104 T.C. 408, 410-411 (1995); Harper v.
Commissioner, supra; see also Chambers v. NASCO, Inc., 501 U.S.
32 (1991). To give full effect to our award of attorney's fees
and costs, we exercise our inherent power and grant petitioners
interest on such award. Cf. BankAtlantic v. Blythe Eastman Paine
Webber, Inc., 12 F.3d 1045, 1052-1053 (11th Cir. 1994). In
particular, the decisions that we shall enter in the test cases
and the orders we shall issue in the nontest cases will provide
that interest will accrue in petitioners' favor--from the date of
such decisions and orders--at the applicable rates for
underpayments under sections 6601(a) and 6621(a)(2).16
II. Additional Sanctions
In addition to requesting an award of attorney's fees and
costs, Mr. Sticht contends that we should (1) adjust the
Rinaldis' tax liabilities for taxable years prior to 1987 in
accord with the 20-percent settlement offer that respondent
withdrew on December 31, 1986, (2) eliminate the Rinaldis' tax
liabilities for taxable years after 1986, and (3) eliminate the
Rinaldis' liability for interest after December 31, 1986. Mr.
Sticht bases his requests for relief on the assumptions that, had
16 Contrary to petitioners' request, we shall not direct
respondent to pay immediately the awards in question. We shall
simply include the amount of the award in each decision and order
referred to above.
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