Opinion
24703-21
05-11-2023
NORTH DONALD LA PROPERTY, LLC, NORTH DONALD LA INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
This case is calendared for trial at an initial special session of the Court beginning September 9, 2024, and a second special session beginning October 7, 2024, both in Atlanta, Georgia. The case involves a charitable contribution deduction claimed by North Donald LA Property, LLC (North Donald) for a conservation easement.
On May 3, 2023, respondent filed a Motion for Partial Summary Judgment in which he seeks a ruling that petitioner and Welsh Land Investors, LLC were not members of North Donald as of the date the easement was purportedly contributed and so are not entitled to any allocation of the deduction claimed by North Donald. Respondent represents that petitioner objects to the granting of this Motion.
In consideration of the foregoing, it is
ORDERED that petitioner shall file, on or before June 9, 2023, a Response to the Motion for Partial Summary Judgment.