Opinion
13925-17
12-09-2022
LAKEPOINT LAND II, LLC, LAKEPOINT LAND GROUP, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler, Judge
On August 11, 2022, respondent filed a Motion for Partial Summary Judgment seeking a ruling from the Court on the IRS' compliance with I.R.C. section 6751(b) with respect to the assertion of penalties in this matter. Attached to the Motion for Partial Summary Judgment is a Declaration from Catherine C. Brooks, a Programs Manager with the IRS.
On December 7, 2022, a conference call with the Court and the parties was held regarding readiness for trial. Considering the discussion of the parties and their readiness for trial, the Court is inclined to set this case for trial in the fall of 2023.
In consideration of the foregoing, it is
ORDERED that this case is set for trial, at a special trial session of the Court, beginning at 10:00a.m. (EST) Monday, October 2, 2023 at the United States Tax Court, Russell Federal Building & Courthouse, 75 Ted Turner Dr., S.W., Room 1136, Atlanta, GA 30303. It is further
ORDERED that if trial of this matter is not concluded during the week of October 2, 2023, trial of this case will resume beginning at 10:00a.m. (EST) Tuesday October 10, 2023, at the United States Tax Court, Russell Federal Building & Courthouse, 75 Ted Turner Dr., S.W., Room 1136, Atlanta, GA 30303. It is further
ORDERED that on or before January 27, 2023, the parties shall file with the Court a joint (or separate, if preferred) status report listing proposed pretrial deadlines for discovery, contradictory motions, exchange of proposed exhibits, expert reports (if any) and any rebuttals (if any), pretrial memoranda and stipulation of facts. It is further
ORDERED that a telephone status conference with the Court and the parties herein is set for August 16, 2023, at 11:00a.m. (EST) to discuss trial preparation of this matter. The Court will separately furnish counsel for the parties dial-in information for the telephone status conference, and if counsel for the parties are unavailable at this scheduled time, counsel is to notify Chambers by calling (202) 521-0649 as soon as possible. It is further
ORDERED that petitioner is to file a response on or before January 27, 2023, to respondent's Motion for Partial Summary Judgment, filed on August 11, 2022.