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delay. Petitioners’ conduct in this case has convinced us that
delay was in fact the primary purpose behind this proceeding.
Petitioners’ repeated failure to comply with respondent’s
discovery requests, even in the face of orders from the Court
directing them to do so, has resulted in a waste of limited
judicial and administrative resources that could have been
devoted to resolving bona fide claims of other taxpayers. See
Cook v. Spillman, 806 F.2d 948 (9th Cir. 1986). Accordingly, we
shall grant respondent’s motion and require petitioners to pay a
penalty to the United States pursuant to section 6673 in the
amount of $12,500.
To reflect the foregoing,
An appropriate order and order
of dismissal and decision shall be
entered.
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Last modified: May 25, 2011