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petitioners’ counsel, Joe Alfred Izen, Jr. (Izen), under section
6673(a)(2)(A). Unless otherwise indicated, all section
references are to the Internal Revenue Code in effect for the
years in issue, and all Rule references are to the Tax Court
Rules of Practice and Procedure.
Background
The petitions in these cases were filed by Johnson,
individually and as trustee of the NJSJ Trust, on April 5, 1999.
In each case, Houston, Texas, was designated by petitioners as
the place of trial, although Johnson resided in Indiana at the
time. The cases were first set for trial at a session set for
Houston on October 25, 1999. Izen entered his appearances in
these cases on August 4, 1999, and October 18, 1999,
respectively. Izen is a resident of Texas.
On or about 75 days before the October 25, 1999, trial date,
the last day for serving formal discovery in accordance with Rule
70(a)(2), respondent served first sets of interrogatories and
requests for production of documents on petitioners. Thirty days
later, on the last day for filing motions to compel discovery,
respondent filed motions to compel responses to the first sets of
interrogatories and requests for production of documents,
requesting sanctions in the event that petitioners failed to
comply with Court-ordered discovery. Respondent’s motions to
compel discovery were granted.
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