|FORMS: 11.7 OBJECTION TO REQUEST FOR MORE TIME BY THE IRS|
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This is a sample pleading which asks the district court to deny an IRS motion for more time.
Plaintiff prays that the Court deny defendant's request for an extension of time to respond to his complaint, on the following grounds:
a) Requests for extension of time are normally made in circumstances where the party experiences a genuine emergency, such as accident, injury, illness, giving birth, unexpected relocation, employment problem, and so on.
b) Defendant has not experienced any such genuine emergency, but merely desires an extension 'in order to submit a more thorough response".
c) Defendant is the most powerful secular entity on this planet, having financial and material resources far greater than that of plaintiff, including enormous wealth and an entire staff of attorneys dedicated to defending tax complaints. These resources already give defendant an immense advantage over plaintiff, who is an individual representing himself.
d) Under federal regulations, defendant already has twice the time (60 days) of that allowed an individual (30 days) in which to answer a complaint, which further increases defendant's advantage.
e) Plaintiff argues that defendant has had enough time to prepare its answer, and that it has not shown a sufficiently good cause or compelling reason why an extension of time should be granted.
f) Plaintiff argues that defendant already has an immense advantage, and that it would be blatantly unjust to further increase its advantage by granting an extension of time.
g) Plaintiff argues that if extensions of time were granted to all defendants 'in order to prepare a more thorough response', the judicial system would grind to a halt, hence it is contrary to the administration of justice to encourage this type of frivolous behavior.
Dated May 5, 2000
Plaintiff in propria persona