- 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).
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