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Court. We are convinced that petitioner instituted and
maintained these proceedings primarily for delay. Although the
amount is scarcely sufficient,3 we shall impose a penalty of
$25,000 pursuant to section 6673.
III. Additional Sanctions
As we stated in Williams v. Commissioner, 119 T.C. 276, 281-
282 (2002) (citations omitted):
all courts are vested with the inherent “power to
impose silence, respect, and decorum, in their
presence, and submission to their lawful mandates”. It
is established that this Court has
inherent power and authority to regulate and
supervise proceedings before it so as to
insure the integrity of its processes. The
Court's inherent power extends to regulate
both conduct before it and conduct beyond its
confines. The Court has recognized its
authority to maintain the integrity of its
proceedings and its ability to provide relief
for a party's misconduct.
In addition to our inherent power, section 7456(c), as
pertinent to this case, provides that
The Tax Court and each division thereof shall
have power to punish by fine or imprisonment,
at its discretion, such contempt of its
authority, and none other, as--
(1) misbehavior of any person in its
presence or so near thereto as to obstruct
the administration of justice; * * *
3 We note that the original version of the sec. 6673
penalty dates back to 1926; however, Congress has not raised the
amount of the sec. 6673 penalty since 1989. See Omnibus Budget
Reconciliation Act of 1989, Pub. L. 101-239, sec. 7731(a), 103
Stat. 2400. For a discussion of the history of sec. 6673, see
Wilkinson v. Commissioner, 71 T.C. 633 (1979).
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