Jimmie L. Williams and Annie W. Williams, Deceased, Jimmie L. Williams, Personal Representative - Page 2




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                    Held:  R’s motion will be granted.  P is liable                   
               for a criminal fine under sec. 7456, I.R.C., as a                      
               sanction for his misbehavior.                                          


               Jimmie L. Williams, pro se.                                            
               Michael W. Berwind, for respondent.                                    


                                       OPINION                                        
               GERBER, Judge:  Respondent moved to dismiss this case for              
          lack of prosecution and for sanctions to be imposed on Jimmie L.            
          Williams (hereinafter petitioner).  Respondent points out that              
          petitioner has been unresponsive to requests to settle or engage            
          in pretrial preparation in accord with this Court’s Rules and               
          orders.  Respondent also contends that petitioner intentionally             
          and unnecessarily delayed and protracted this proceeding and                
          that a section 66731 penalty of $25,000 should be imposed upon              
          petitioner.  In addition to the section 6673 penalty, respondent            
          contends that petitioner should be sanctioned or fined $5,000               
          because of petitioner’s misconduct and intentional avoidance of             
          this Court’s legal orders, Rules, decrees, or commands.                     
          Respondent has shown that petitioner has intentionally                      
          misrepresented facts in the form of oral and written                        


               1 All section references are to the Internal Revenue Code,             
          in effect for the years in issue, and all Rule references are to            
          the Tax Court Rules of Practice and Procedure, unless otherwise             
          indicated.                                                                  





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