Opinion
10819-21
02-09-2023
PARKWAY GRAVEL, INC. AND SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
On February 7, 2023, the Commissioner filed a motion for in camera review of certain documents inadvertently produced on January 4, 2023, by Horty & Horty, P.A., the accounting firm for the petitioner, Parkway Gravel, Inc. and Subsidiaries (Parkway), during the years at issue in this case.
The Commissioner requests the Court to find that the documents are not privileged, and may be viewed and potentially used by the Commissioner, or order Parkway to show cause that the particular documents are subject to privilege and why any such privilege with respect to the documents at issue and/or their subject matter has not been waived. We will direct Parkway to file a response to the motion. After due consideration, it is
ORDERED that, on or before February 15, 2023, Parkway shall file a response to the motion for in camera review.