Jimmie L. Williams and Annie W. Williams, Deceased, Jimmie L. Williams, Personal Representative - Page 14




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          Ryan v. Commissioner, supra at 223, this Court imposed a $1,000             
          criminal fine for repeated contumacious failure to answer                   
          interrogatories.  In this case, petitioner also ignored and                 
          attempted to avoid this Court’s order enforcing respondent’s                
          discovery request by interposing the automatic stay.  In this               
          case, petitioner intentionally misrepresented and wrongfully                
          interposed the automatic stay to frustrate and ignore the lawful            
          orders, Rules, and process of this Court.  The effect of                    
          petitioner’s conduct in this case is more serious and more                  
          deceitful than the taxpayer’s conduct in Ryan.  We note that the            
          $1,000 fine in Ryan was imposed more than 25 years ago.                     
               In order to impress petitioner with the seriousness of this            
          matter and to fine him for his conduct in criminal contempt of              
          this Court, we hold petitioner unconditionally liable for a fine            
          of $5,000.                                                                  
               To reflect the foregoing,                                              

                                             An appropriate order and                 
                                        decision will be entered for                  
                                        respondent.                                   














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