Frank A. Luca and Sherry L. Luca - Page 11

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          at a minimum we would have expected Mr. Luca to provide us with               
          copies of correspondence to authorities allegedly in possession               
          of his business records.  Instead, Mr. Luca failed to file the                
          required status report, and we have no indication that Mr. Luca               
          has undertaken any efforts to obtain the documentation necessary              
          to support his case.  In addition, Mr. Luca failed to comply with             
          our order that he respond to the motion to dismiss presently                  
          before us.                                                                    
               While a taxpayer has an interest in having his or her case               
          heard on the merits, the Commissioner has the right to obtain                 
          judicial resolution of tax disputes within a reasonable period of             
          time.  See Freedson v. Commissioner, supra at 935.  As this case              
          heads into its fourth year before the Court, respondent’s                     
          interest in obtaining a resolution of the tax liabilities at                  
          issue becomes increasingly compelling.                                        
               In balancing the interests of Mr. Luca against those of                  
          respondent, we find that the considerations in this case favor                
          respondent.  Simply put, Mr. Luca has not provided the Court with             
          any indication that he intends to move this case forward in the               
          foreseeable future.  The remedy of dismissal is admittedly harsh,             
          but we see no alternative that will adequately protect the                    
          interests of respondent.  “Although a court must explore                      
          meaningful alternatives prior to dismissing a case, it need not               
          always exhaust every sanction short of dismissal before final                 

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