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does not file a reply as directed herein, the Court will grant
respondent's motion and deem admitted for purposes of this case
the affirmative allegations in the answer." Upon petitioner's
failure to file a reply, the Court granted respondent's motion
and deemed admitted the affirmative allegations of fact set forth
in respondent's answer.
On April 27, 1999, the Court issued the notice of trial for
the instant case for the trial session in Los Angeles,
California, on September 27, 1999.
On June 21, 1999, respondent filed a motion for partial
summary judgment based upon the allegations in respondent's
answer, which allegations were deemed admitted pursuant to Rule
37(c). On June 22, 1999, the Court ordered petitioner to file a
response to the motion for partial summary judgment on or before
July 22, 1999. Petitioner failed to file a response. On June
21, 1999, respondent filed a request for admissions pertaining to
the addition to tax for delinquency under section 6651(a)(1).
Petitioner failed to file a response to respondent's June 21,
1999, request. On August 24, 1999, respondent filed a second
motion for partial summary judgment based upon the admissions as
to the addition to tax under section 6651(a)(1).2 On August 27,
1999, the Court ordered petitioner to file a response to
2 Taken together, respondent's motions for partial summary
judgment, if granted, dispose of all of the issues in the instant
case.
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Last modified: May 25, 2011