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inherent power and authority to regulate and supervise
proceedings before it so as to insure the integrity of
its processes. See Freytag v. Commissioner, 501 U.S.
868, 891 (1991); Chambers v. NASCO, Inc., 501 U.S. 32,
43-46 (1991). The Court’s inherent power extends to
regulate both conduct before it and conduct beyond its
confines. See Chambers v. NASCO, Inc., supra at 44.
The Court has recognized its authority to maintain the
integrity of its proceedings and its ability to provide
relief for a party’s misconduct. See, e.g. Dixon v.
Commissioner, T.C. Memo. 2000-116 (imposing additional
sanctions, some on the basis of inherent power); Dixon
v. Commissioner, T.C. Memo. 1999-101; CMEM, Inc. v.
Commissioner, T.C. Memo. 1991-467.
Crop Associates-1986 v. Commissioner, T.C. Memo. 2000-216.
In addition to our inherent power, section 7456(c), as
pertinent to this case, provides that
The Tax Court and each division thereof shall have
power to punish by fine or imprisonment, at its
discretion, such contempt of its authority, and none
other, as--
(1) misbehavior of any person in its presence or
so near thereto as to obstruct the administration of
justice;
* * * * * * *
(3) disobedience or resistance to its lawful writ,
process, order, rule, decree, or command.
We consider, however, whether it would be appropriate to
impose a sanction on petitioner in addition to the $25,000
penalty for his institution or maintenance of this proceeding for
purposes of delay. The $25,000 penalty under section 6673, as
explained above, was imposed because of petitioner’s obvious
pattern of delay and extensive waste of the resources of the
court system and the Government. However, petitioner’s false
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