-8-
Schulz and other tax professionals after disclosing all of the
relevant facts to them.2
B. Procedural History
This case was set for trial in Louisville, Kentucky, several
times, but was continued on November 7, 1997, September 30, 1998,
December 22, 1999, and February 6, 2001. This case was called
for report at the February 5, 2001, Louisville, Kentucky, trial
session and set for trial at a special session of the Court to
begin on April 23, 2001. A stipulation of facts was filed on
April 3, 2001. However, the case was continued on April 17,
2001, and the special session was canceled.
Motions to withdraw filed by petitioner’s counsel Robert C.
Webb and Scott William Dolson were granted on January 9, 2002,
and September 5, 2002.
Petitioner, his adult son, and respondent had several
discussions in an effort to narrow the issues or resolve this
case, as ordered by the Court on October 1, 2003. The
discussions did not result in a narrowing of the issues. Around
February 9, 2004, petitioner’s son told respondent’s counsel that
2 On Mar. 22, 2001, an amendment to petition was filed in
which petitioner alleged that respondent was barred by the
doctrines of collateral estoppel, res judicata, and waiver, and
by sec. 6212 from proceeding with this case. On May 1, 2001, an
answer to amended petition was filed in which respondent denied
the allegations in the amendment to petition.
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