J. David Golub - Page 16




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          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.                     







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