Larry Brown - Page 10

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          petitioner's failure to comply with this Court's discovery order            
          of April 9, 1997.  Respondent requested that the following                  
          sanctions be imposed by the Court:  (1) That this action be                 
          dismissed; (2) that the issues to which respondent's discovery              
          requests pertain be taken as established as set forth in the                
          notice of deficiency; (3) that all answers covered by                       
          respondent's request which petitioner should have made available            
          in response to respondent's interrogatories be excluded from                
          evidence in this case; (4) that all documents covered by                    
          respondent's request which petitioner should have made available            
          in response to respondent's request be excluded from evidence;              
          and (5) that the Court grant such other relief as it may deem               
          proper.                                                                     
               Respondent also filed a Motion for Partial Summary Judgment            
          (Summary Judgment Motion) with accompanying memorandum of law and           
          declaration in support thereof pursuant to Rule 121(b) on August            
          25, 1997, on the issue (informally raised by petitioner during an           
          IRS Appeals Office conference but not raised by petitioner in               
          this proceeding) whether the 3-year period of limitations for               
          assessment has expired because the Partnership allegedly elected            
          treatment under the unified audit provisions of Subtitle F,                 
          Chapter 63, Subchapter C, secs. 6221 through 6233, for taxable              
          years 1992 and 1993, and respondent did not honor such election.            
               By Order dated August 26, 1997, the Court ordered that                 
          petitioner respond, on or before September 10, 1997, to                     




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