Opinion
25141-22L
05-02-2024
THOMAS BLACKWELL & POLLY BLACKWELL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Diana L. Leyden, Special Trial Judge
Pending in this case is respondent's Motion to Dismiss for Lack of Jurisdiction, filed August 23, 2023 (motion to dismiss). By Order served March 28, 2024, the Court directed the parties to each file a memorandum of law by April 29, 2024, or other response to the Order, addressing the application of the Court's opinion in Organic Cannabis Found., LLC v. Commissioner, 161 T.C. No. 4 (Sep. 27, 2023) to the facts of this case.
On April 26, 2024, the parties jointly filed a Motion for Extension of Time, moving the Court to extend the time within which the parties have to each file a memorandum of law as directed by the Court. In the Motion for Extension of Time the parties further informed the Court that the parties anticipated settlement of the case. The parties requested that, should they not reach a resolution, they would each file a memorandum of law by May 31, 2024.
Upon due consideration, it is
ORDERED that the parties' joint Motion for Extension of Time, filed April 26, 2024, is granted, and the time within which the parties shall each file a memorandum of law, or other response, to the Court's March 28, 2024, Order is extended to May 31, 2024.