- 22 -- 22 - respondent’s management the question whether Mr. Chisum’s conduct in this and other cases has created an appropriate occasion for imposition of tax shelter promoter/operator penalties under section 6700 or section 6701, cf., e.g., Kersting v. United States, 206 F.3d 817 (9th Cir. 2000), an action for injunctive relief under section 7408(a), action to enjoin promoters of abusive tax shelters, etc., cf. e.g., United States v. Raymond, 228 F.3d 804 (7th Cir. 2000), or a criminal investigation of the type that culminated with Mr. Mayer’s indictment and conviction. See supra note 10.14 In accordance with the foregoing, An order will be entered denying petitioner’s Motion To Dismiss and granting respondent’s Motion To Dismiss for Lack of Jurisdiction. 14 See IRS website on abusive trusts, “www.treas.gov/irs/ ci”, describing criminal enforcement activities against Mr. Mayer and others. See also Hamilton, IRS Crackdown on Abusive Trusts Producing Convictions, Highlights & Documents (Oct. 2, 2000).Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22
Last modified: May 25, 2011