Aruba Bonaire Curacao Trust Company Limited, Trustee of Supriano Trust v. Commissioner of Internal Revenue

MCGOWAN, Senior Circuit Judge:

In this case, the Tax Court, dismissed appellants’ pending actions as a sanction for failure to present evidence at a discovery hearing. Because we find that the Tax Court had authority to dismiss these actions and did not abuse its discretion in so doing, we affirm.

I. The Pacts

A. The Underlying Tax Dispute

Aruba Bonaire Curacao Trust Company, Limited (“ABC”) is the non-resident alien trustee of the four trusts that are the subject of this action. Pursuant to its duty to manage the trusts’ assets prudently, ABC invested in several land development projects in…