- 4 - The case was set for trial on May 23, 1994. Petitioners were served with the Court's Standing Pre-Trial Order on December 22, 1993. This order advised petitioners to begin discussions with respondent as soon as practicable for purposes of settlement and/or preparation of a stipulation of facts. In January 1994, respondent attempted to confer informally with petitioners in order to clarify the issues involved, and to develop and stipulate where possible the pertinent facts. By letter dated January 20, 1994, respondent suggested that petitioners meet with respondent's counsel on February 1, 1994, or at a more convenient time, to discuss the case. Attached to this letter was a proposed stipulation of facts and copies of pertinent Tax Court Rules. Petitioners failed to respond in any way to the January 20, 1994, letter. By letter dated February 16, 1994, respondent informed petitioners that due to their failure to appear for the scheduled meeting or to arrange another meeting date, respondent would proceed with discovery under the assumption petitioners would not abide by the Tax Court Rules. This letter also informed petitioners they would be receiving a request for admissions shortly, and warned petitioners of sanctions the Tax Court could impose for failure to respond to the request. Petitioners did not respond to this letter. Respondent then served petitioners with a Request for Admissions on March 8, 1994, pursuant to Rule 90. The requestPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011