Opinion
6585-21
12-18-2023
OGEECHEE PLANTATION PROPERTY, LLC, OGEECHEE PLANTATION MANAGER, 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 spoke with the parties on July 19, 2022 to discuss how the case can best be developed. We learned that this case is closely related with another one on the calendar, Belford Oaks v. Commissioner - in both the subject property was divided from the same, larger parcel. Two more cases, also involving property divided from that same large parcel, docket numbers 11559-23 and 11560-23, are now before the Court. They all present similar questions of valuation and possibly similar legal questions. Both parties continue to stress that they are only in the earliest stages of pretrial development. It continues to makes sense to keep the case on a somewhat longer status-report track and it is
ORDERED that on or before February 16, 2024 the parties shall file a status report to describe their progress in informal discovery. They should include a brief description of their views on whether these cases (including the two newest ones) should be consolidated, whether these four cases should be grouped with other conservation-easement cases, and whether it makes sense to move them onto a pre-trial order track.