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Most of the requested admissions regarded respondent’s opinion
about the Sixteenth Amendment and whether the income tax was a
direct or indirect tax. On May 18, 2001, respondent filed a
response to petitioner’s request for admissions.
On May 29, 2001, petitioner filed a motion for review of
response to petitioner’s request for admissions. Petitioner
alleged that respondent’s responses to petitioner’s paragraphs
regarding respondent’s opinion about the Sixteenth Amendment and
whether the income tax was a direct or indirect tax were
insufficient.5
On July 7, 2001, the Court denied petitioner’s motion for
review of response to petitioner’s request for admissions. The
Court found that respondent’s answers were sufficient.
On August 3, 2001, petitioner filed a motion to reconsider
the Court’s order of July 7, 2001. Petitioner stated that he was
seeking respondent’s position on a point of law regarding the
nature of the income tax. On August 6, 2001, the Court denied
this motion.
On September 4, 2001, petitioner filed a motion for leave to
file interlocutory appeal seeking review of the Court’s denial of
petitioner’s motion to reconsider Court’s order of July 7, 2001.
Petitioner stated that he was seeking respondent’s “policy and
5 Respondent objected to these paragraphs on the ground
that the request for admissions sought admissions based on
statements of law rather than statements of fact.
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