J. Thomas and Henrietta A. Hardin - Page 13

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          that could have and should have been resolved at the audit stage            
          had petitioners been willing to pursue administrative remedies.             
               Petitioners have shown disregard for the tax laws and the              
          Rules of this Court.  We believe that petitioners will continue             
          to do so unless and until they are sent a message that their                
          behavior is unacceptable.  We are acutely aware that petitioner             
          is an officer of the court, not only as a practicing attorney,              
          but also as a referee or hearing officer involving family law               
          matters.  As such, petitioner should appreciate the importance of           
          following this Court’s Rules and not wasting the limited                    
          resources of the Government.                                                
               Petitioners have displayed a complete lack of interest in              
          presenting their case and have repeatedly ignored respondent’s              
          requests for substantiation of the claimed deductions.  We                  
          therefore conclude that petitioners initiated this proceeding               
          primarily for delay and have unreasonably failed to pursue                  
          available administrative remedies.  Accordingly, we require                 
          petitioners to pay a penalty of $10,000 to the United States                
          pursuant to section 6673.                                                   
               To reflect the foregoing,                                              

                                             An appropriate order and                 
                                        order of Dismissal for Lack of                
                                        Prosecution and a Decision will be            
                                        entered under Rule 155.                       




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