- 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.
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Last modified: May 25, 2011