- 2 - arising from petitioners’ failure to substantiate certain expenses for 1996. The trial of this case was scheduled for the Court’s Louisville, Kentucky, trial session commencing September 8, 2003 (Louisville trial session). When this case was called at calendar, petitioners failed to appear. Respondent moved to dismiss the case for petitioners’ lack of prosecution. We grant respondent’s motion to dismiss for lack of prosecution. Respondent also moved to impose sanctions under section 6673 against petitioners for instituting these proceedings primarily for delay and for petitioners unreasonably failing to pursue available administrative remedies. An evidentiary hearing was held.3 We shall impose a penalty against petitioners under section 6673. Background Petitioners resided, at the time they filed the petition, in Inez, Kentucky. Petitioner,4 licensed to practice law in Kentucky and West Virginia, was a self-employed attorney involved in the general 2(...continued) indicated. 3 The Court heard testimony from Agent Anna Lou Dary, who handled the audit, and Appeals Officer Elmer L. Craig. The testimony related to the accuracy-related penalty under sec. 6662(a) and sec. 6673. 4 References to petitioner individually are to J. Thomas Hardin, and the claimed deductions relate to his businesses, not to those of Henrietta A. Hardin.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011