- 21 -- 21 - 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 withPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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