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In the motion for interlocutory review, petitioner requested
interlocutory review of all the orders of the Court and stated:
“This notice intends also to cover prospectively any such order
as it becomes a decision of the Tax Court.”
On April 28, 2004, the Court denied petitioner’s motion for
stay, motion for judgment on the pleadings, and motion for
interlocutory appeal.
On May 12, 2004, the Court notified respondent that
petitioner had filed on April 2, 2004, a motion to shift the
burden of proof and that if there was an objection, a notice of
objection had to be filed on or before June 1, 2004.
On May 28, 2004, respondent filed an objection to
petitioner’s motion to shift the burden of proof, and pursuant to
Rule 37, filed a motion for entry of order that undenied
allegations in the answer to the amended petition be deemed
admitted.
On June 4, 2004, the Court denied petitioner’s motion to
shift the burden of proof. The Court also notified petitioner
that respondent had filed on May 28, 2004, a motion for an order
that the specified affirmative allegations in the answer be
deemed admitted; that if petitioner filed a reply as required by
Rule 37 on or before June 24, 2004, respondent’s motion would be
denied; and that if petitioner did not file a reply, the Court
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