Free Motion for Extension of Time to File Response/Reply - District Court of Federal Claims - federal

Case 1:06-cv-00245-EJD

Document 77

Filed 07/17/2008

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IN THE UNITED STATES COURT OF FEDERAL CLAIMS Nos. 06-245T, 06-246T, and 06-247T
(Consolidated)

MURFAM FARMS, LLC, By and Through Wendell H. Murphy, Jr., a Partner Other Than Tax Matters Partner,

PSM FARMS, LLC, By and Through Stratton K. Murphy, a Partner Other Than Tax Matters Partner, MURPHY PORK PARTNERS, LLC By and Through Wendell H. Murphy, Jr. a Partner Other Than Tax Matters Partner, Plaintiffs, v. UNITED STATES OF AMERICA, Defendant.

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____________ UNITED STATES' EMERGENCY MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO PLAINTIFFS' MOTION TO CONFIRM JURISDICTION ___________ The United States moves this Court to enter an order for an enlargement of time for defendants' response to plaintiffs' motion to confirm jurisdiction, presently due on July 21, to August 1. The United States has requested the views of the Internal Revenue Service regarding some of the issues raised in plaintiffs' motion. The Internal Revenue Service has requested additional time to provide its views on these matters. 1

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Case 1:06-cv-00245-EJD

Document 77

Filed 07/17/2008

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Therefore, the United States respectfully requests that the Court grant its motion for an enlargement of time to respond to plaintiffs' motion to confirm jurisdiction until August 1.

Respectfully submitted,

s/ Dennis M. Donohue DENNIS M. DONOHUE CHIEF SENIOR LITIGATION COUNSEL OFFICE OF CIVIL LITIGATION Trial Attorney, Tax Division U.S. Department of Justice P.O. Box 55, Ben Franklin Station Washington, D.C. 20044 Telephone: (202) 307-6492 Facsimile: (202) 307-2504 E-mail: [email protected]

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Case 1:06-cv-00245-EJD

Document 77

Filed 07/17/2008

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CERTIFICATE OF CONFERENCE On July 16 and 17, 2008, I spoke to Mr. Anthony Daddino, an attorney for plaintiffs and asked if plaintiffs would oppose the government's motion for an enlargement of time. Mr. Daddino informed me that plaintiffs would oppose the motion.

s/ David M. Steiner David M. Steiner Trial Attorney, Tax Division U.S. Department of Justice Post Office Box 55 Ben Franklin Station Washington, D.C. 20044 (202) 307-5892

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Case 1:06-cv-00245-EJD

Document 77

Filed 07/17/2008

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CERTIFICATE OF SERVICE I hereby certify that on July 171h, 2008, I electronically filed the foregoing UNITED STATES' EMERGENCY MOTION FOR ENLARGEMENT OF TIME with the Clerk of the Court using the ECF system which will send notification of such filing to the following: Joel N. Crouch Texas State Bar No. 05144220 Meadows, Collier, Reed Cousins & Blau, L.L.P. 901 Main Street, Suite 3700 Dallas, Texas 75202

s/ David M. Steiner David M. Steiner Trial Attorney, Tax Division U.S. Department of Justice Post Office Box 55 Ben Franklin Station Washington, D.C. 20044 (202) 307-5892

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