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in the alternative an increased deficiency in, and increased
additions to, Life Center’s 1996 tax. Petitioners did not file a
reply to respondent’s amendment to answer.
Petitioners’ Discovery Requests
On September 27 and 28, 2001, petitioners served on
respondent a request for admissions, a set of interrogatories,
and two requests for production of documents. The request for
admissions is 134 pages in length (without attachments) and
requests 545 admissions. The set of interrogatories is 124 pages
in length and contains 480 interrogatories.
On October 5, 2001, respondent filed a motion for protective
order with respect to the request for admissions,
interrogatories, and requests for production of documents served
by petitioners. Respondent argued that such requests were not
timely, addressed improper issues, and were intended to burden
respondent unduly, waste his resources, and divert him from trial
preparation. We asked petitioners to respond and, after
considering their response, granted respondent relief
“substantially for the reasons stated in respondent’s motion.”
Petitioners’ Dismissal Efforts
Motion To Dismiss for Lack of Jurisdiction
On November 21, 2001, petitioners submitted a motion styled
“Petitioner’s Verified Challenge to Jurisdiction of the Court”,
which we filed as a motion to dismiss for lack of jurisdiction.
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