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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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