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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