Opinion
12271-20 12274-20
03-30-2023
JACKSON STONE SOUTH, LLC, JACKSON SOUTH INVESTMENTS, LLC, TAX MATTERS PARTNER, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall Judge
This case is before the Court on petitioners' Motion to Impose Sanctions, filed March 22, 2023. On March 20, 2023, the Court held a hearing on petitioners' motion. At respondent's request, the Court did not rule on the Motion to Impose Sanctions at that time. On March 22, 2023, the Court again addressed the Motion to Impose Sanctions with the parties and denied it at that time.
Petitioners' motion inaccurately characterizes respondent's conduct. It is overreaching, inappropriate, and lacks merit. The Court again reminds the parties of paragraph 20 of the Preamble and Scope of the Model Rules of Professional Conduct of the American Bar Association, which states in part that: "the purpose of the Rules can be subverted when they are invoked by opposing parties as procedural weapons." See Rule 201(a), Tax Court Rules of Practice and Procedure. The Court does not see any need to discuss the motion further.
Upon due consideration and for reasons set forth more fully in the transcript of the above-referenced proceedings, it is
ORDERED that petitioners' Motion to Impose Sanctions, filed March 22, 2023, is denied.