Jimmie L. Williams and Annie W. Williams, Deceased, Jimmie L. Williams, Personal Representative - Page 10




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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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