- 3 - February 9, 2004, Philadelphia, Pennsylvania, trial session. A notice setting case for trial, dated September 4, 2003, and a standing pretrial order were sent to petitioner. On January 15, 2004, petitioner moved for a continuance on the grounds that he needed more time to negotiate a settlement with the Appeals officer and to liquidate the assets necessary to satisfy any tax liability resulting from the settlement. Petitioner’s motion for continuance stated in part the following: There are a litany of reasons for my request for continuance. As a courtesy I will just specify one of the main ones. * * * I need a continuance in order to work out the settlement. The glitch is in the payoff of the settlement. If [the Appeals officer] * * * and I agree on a “low-end” settlement amount then I can just give him a check and the matter is concluded. If however the settlement amount is near the high end of the spectrum, I will have to pay using non-cash assets. It can take several months to establish the value of these assets since the potential buyers are scattered throughout the country. [The Appeals officer’s] * * * patience and flexibility in dealing with these asset liquidation issues is material to settlement of the case--for without these I would likely be motivated to pursue the litigation option. The postponement of my court date by at least several months would be ideal, although I’m realistic enough to know you may have limits. Again, if you find this reason to be insufficient, please notify me and I can have additional reasons overnighted to you since there are so many reasons. * * * Respondent objected to the continuance, stating that petitioner failed to attend every conference that counsel for respondent or the Appeals officer had scheduled, after providing notice of hisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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