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Petitioner’s Motions
A. Petitioner’s Motion To Remove Small Tax Case Designation
On October 7, 2005, petitioner filed a Motion To Remove
Small Tax Case Designation. In the motion, petitioner alleges:
At the time he made the small tax case designation,
Petitioner did not at all comprehend the import of the
respondent’s not having to file an answer to his
amended petition and the petitioner’s (and the
respondent’s) inability to appeal any adverse decision
of this Court to a Circuit Court of Appeals.
Petitioner did not state whether respondent objected to the
motion.
B. Petitioner’s Motion For Leave To File Second Amended
Petition
Also on October 7, 2005, petitioner filed a Motion For Leave
To File A Second Amended Petition. Petitioner lodged a proposed
second amended petition with the motion for leave. In support of
his motion for leave, petitioner alleges that the amended
petition “neither adequately sets forth grounds of error in
respondent’s determination, nor facts in support thereof, in
sufficient detail to apprise both the Court and respondent of
petitioner’s actual litigating position” and that the second
amended petition sets forth “only substantive and non-frivolous
arguments”. Petitioner did not state whether respondent objected
to the motion. Petitioner also requested that the Court hold
respondent’s motion for summary judgment in abeyance.
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Last modified: May 25, 2011