- 7 - Petitioner’s contentions, as contained in its motion for partial summary judgment filed November 8, 1999, may be summarized as follows: Petitioner asserts that its motion for partial summary judgment encompasses the doctrine of collateral estoppel. In support of this contention, petitioner cites to a Memorandum Opinion filed by the Bankruptcy Court for the Northern District of Oklahoma on October 1, 1997, and a Memorandum Opinion filed by the Bankruptcy Court on December 18, 1998. Petitioner argues that the October 1, 1997, Memorandum Opinion determined that there were no income tax deficiencies for the fiscal year ended February 28, 1993, and that there was an income tax deficiency for the fiscal year ended February 28, 1994, in the amount of $5,000. Petitioner also appears to argue that the December 18, 1998, Memorandum Opinion2 regarding the confirmation plans of 2 On December 18, 1998, the Bankruptcy Court filed an Order Confirming Plan in which the Court ordered, inter alia: that in accordance with the terms of the Third Amended Plan of Reorganization the estates of Limited Gaming of America, Inc., Case No. 96-00395-M, and Sunrise Island, Ltd., Case No. 96-00396-M, be, and the same hereby are, substantively consolidated. It Is Further Ordered that all pleadings and papers related to the Sunrise Island Ltd. matter, Case. No. 96-00396-M, shall from the date of this Order be filed under Case No. 96-00395-M. We also note that in paragraph 6y of its petition, the petitioner averred: (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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