Anthony D. Long - Page 5

                                        - 5 -                                         
          more time to build his case and gather necessary information, and           
          the parties decided to wait until September 26, 2006, to schedule           
          a meeting.                                                                  
               On September 26, 2006, respondent sent petitioner a letter             
          detailing the informal discovery process under Rule 91 and                  
          requesting that petitioner send copies of all relevant documents            
          to respondent pursuant to Branerton Corp. v. Commissioner, 61               
          T.C. 691 (1974).  Respondent also warned petitioner of the                  
          penalty under section 6673(a)(1) for raising frivolous arguments            
          and instituting proceedings primarily for delay.  On the same               
          day, respondent received a telephone message from petitioner                
          stating that he did not intend to meet with respondent or provide           
          any other documentation.  Petitioner also informed respondent               
          that he would not respond to informal discovery requests and that           
          any further communication would be made only by written                     
              On October 6, 2006, respondent sent petitioner another                 
          letter emphasizing the Court’s requirement to conduct informal              
          discovery and requesting that petitioner respond to the discovery           
          requests.  Respondent proposed a deadline of October 31, 2006,              
          for responses to or requests for informal discovery.  Respondent            
          informed petitioner that the Court has characterized arguments              
          like the ones made by petitioner as frivolous and groundless and            

Page:  Previous  1  2  3  4  5  6  7  8  9  Next 

Last modified: March 27, 2008