Kevin M. Moore - Page 10

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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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