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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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Last modified: May 25, 2011