Opinion
17379-19 17380-19 17381-19 17982-19
01-28-2022
Green Valley Investors, LLC, Bobby A. Branch, Tax Matters Partner, et al Petitioners v. Commissioner of Internal Revenue, Respondent
ORDER
Christian N. Weiler, Judge
On January 21, 2022, petitioners filed unopposed Motions for Leave to File Out of Time Motion for Reconsideration of Order (collectively "Motions for Leave') in each of the above-docketed consolidated cases. Petitioners also lodged their Motions for Reconsideration of Order with their respective Motions for Leave in each of the above-docketed consolidated cases. For good cause shown, the Court is inclined to grant the Motions for Leave and reconsider the interlocutory Order served on May 27, 2021, granting respondent's Motion for Partial Summary Judgment regarding the applicability of Treas. Reg. § 1.170A-14(g)(6)(ii) in these consolidated cases.
Cases of the following petitioners are consolidated herewith: Vista Hill Investments, LLC, Bobby A. Branch, Tax Matters Partner, docket No. 17380-19; Big Hill Partners, LLC, Bobby A. Branch, Tax Matters Partner, docket No. 17381-19; Tick Creek Holdings, LLC, Bobby A. Branch, Tax Matters Partner, docket No.17382-19.
Upon due consideration and for cause, it is
ORDERED that the petitioners' Motions for Leave in each of these consolidated cases are granted. It is further
ORDERED that the Clerk of the Court shall file into the record in each of these consolidated cases, petitioners' Motions for Reconsideration of Order which were previously Lodged with the Court by petitioners, as of the date of this Order. It is further
ORDERED that on or before February 25, 2022, respondent shall file with the Court in each of these consolidated cases and serve on petitioners a response to the Motions for Reconsideration of Order.