- 14 - Respondent filed an answer in which he denied the allegations in the petition and to which he attached a complete index to the administrative record. Respondent did not allege in the answer any new or additional grounds for denying petitioner’s exemption application beyond those grounds identified in the final adverse determination letter. Petitioner did not file a reply or move with respect to the answer. The Court ordered the parties to submit the case on the administrative record or to file a written report as to the then present status of the case. As stated above, because petitioner did not respond to respondent’s written request to stipulate to the administrative record, respondent filed with the Court the entire administrative record, together with the certificate attesting to its genuineness. Subsequently, respondent filed his Motion For Summary Judgment. Petitioner was ordered to file a response to respondent’s motion, but no response was received by the Court. Thereafter, the Court issued an Order, placing respondent’s Motion For Summary Judgment on a motions calendar assigned to Special Trial Judge Armen, who was authorized to hear the matter and make the decision of the Court. See sec. 7443A(b)(1), (c); Rule 218(a); Deleg. Order No. 45, 126 T.C. VI (June 1, 2006). At the hearing, counsel for respondent appeared and argued in support of respondent’s motion. In contrast, there was noPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: March 27, 2008