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trustee. In addition, there has been no showing that Mr. Chisum
was otherwise authorized to act on behalf of petitioner.
We have considered all allegations and arguments made by
Mr. Chisum that we have not discussed herein; we find them to be
without merit or irrelevant. Accordingly, respondent’s motion to
dismiss for lack of jurisdiction will be granted.
Mr. Chisum, Section 6673, and Other Sanctions
During the trial of Johnston v. Commissioner, T.C. Memo.
2000-315, respondent’s counsel asked the Court to consider
imposing a penalty on Mr. Chisum under section 6673. However,
respondent’s counsel later informed the Court that respondent
would not move for a penalty against Mr. Chisum, in either
Johnston or the case at hand. Under all the circumstances of the
case at hand, we do not impose a penalty on Mr. Chisum.
We would not presume to try to tell respondent how to do his
job, see United States v. Payner, 447 U.S. 727, 737 (1980)
(Burger, C.J., concurring) (Supreme Court has no general
supervisory authority over executive branch operations),
particularly in view of the limited resources currently available
to the Internal Revenue Service. However, the expenditures of
time and resources of the Court and the Commissioner in this and
other cases in which Mr. Chisum has acted, see supra note 3, have
been so substantial as to raise the question whether some other
sanction might be appropriate. We therefore leave with
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