- 13 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13
Last modified: May 25, 2011