Kevin M. Moore - Page 11

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          In Williams, as is the case herein, a $25,000 penalty under                 
          section 6673 was imposed because of the taxpayer’s obvious                  
          pattern of delay and extensive waste of the resources of the                
          court system and the Government.  Id. at 282.  In Williams, we              
          considered whether it would be appropriate to impose a sanction             
          on the taxpayer in addition to the $25,000 section 6673 penalty             
          for his institution or maintenance of the proceeding for purposes           
          of delay.  Id.                                                              
               We stated:  “contempt of court may be civil or criminal,               
          depending upon the purpose being served.  ‘[C]ivil contempt is              
          coercive and remedial in character whereas criminal contempt is             
          punitive to vindicate the authority of the Court.’”  Id. at 282-            
          283 (citations omitted).  Because of the possibility of a                   
          monetary fine being imposed as a criminal sanction, the taxpayer            
          was provided with an opportunity to show cause why such a fine              
          should not be imposed.  Id. at 283.                                         
               Although petitioner’s actions herein were contemptuous, we             
          shall not reward petitioner by delaying this matter any further.            
          Perhaps petitioner will see the error of his ways.  Should he               
          return to the Court, however, and proceed similarly (e.g., by               
          engaging in belligerent or disrespectful misbehavior in the                 
          presence of the Court to obstruct the administration of justice),           
          petitioner is on notice that the Court will consider imposing               
          appropriate sanctions pursuant to section 7456(c), in addition to           

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Last modified: November 10, 2007