- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011