- 16 - file a brief, and instead, at the expiration of the extension period, filed a document requesting, inter alia, that the Court vacate several previous orders, stay all proceedings, and further extend the time for filing briefs. In response, the Court issued an order denying all of petitioner’s requests except the extension of time to file an opening brief, for which an additional 7 weeks was given. In that order, however, we advised that petitioner would receive no further extensions of time for filing his opening brief. On the final deadline for filing a brief, petitioner submitted two documents--one entitled “Notice of Interlocutory Appeal” and the other entitled “Motion to Stay All Tax Court Proceedings and Postpone Opening Brief”. The document entitled Notice of Interlocutory Appeal failed to identify a controlling question of law with respect to which there was a substantial ground for difference of opinion and for which an immediate appeal might materially advance the ultimate termination of the litigation herein, as required by Rule 193. In response, we ordered that these two documents be filed, and denied both the motion for leave to file an interlocutory appeal and the motion to stay further Tax Court proceedings. We also ordered that no further briefs in this case would be accepted and that the Court would decide the case on the record presently before it.Page: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011