Opinion
17483-21
02-27-2023
ARDAN HOLDINGS, LLC, ARDAN INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
MARK V. HOLMES, JUDGE.
This case was on the Court's October 24, 2022 trial calendar for Atlanta, Georgia. It is one of many syndicated conservation-easement cases before the Court, and we continued it because the parties will need a considerable amount of discovery. They recently reported continued cooperation in informal discovery. The Court misunderstood the status of petitioners' request to see the administrative file from the promulgation of the qualified-appraiser section of the regulations - respondent's gotten that to petitioners, but he is still working on the administrative file specific to this case. And there is a continued need to fulfill petitioner's FOIA disclosure request. But things are progressing. The parties reasonably suggest reporting again in four months. It is therefore
ORDERED that on or before June 5, 2023 the parties shall file a status report to describe their progress in informal discovery, particularly the status of petitioner's requests for the administrative file for this case, and respondent's progress in gathering the materials requested by petitioner under FOIA.