Opinion
5464-19 5932-19
01-31-2022
RYDER RANCH COMPANY, LLC, ERNEST S. RYDER, TAX MATTERS PARTNER, et al., Petitioners, v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge
The Court released its opinion in a large group of cases related to these, T.C. Memo. 2021-88 last year. These two were assigned to this division of the Court because they are related to the those cases, although they arise from different tax years. We agreed with the parties that it made sense to try to settle the substantiation issues and try to set up for summary judgment the CDP issues. They continue to suggest coordination with the computations in the earlier cases would help. This remains reasonable and it is
ORDERED that on or before April 22, 2022 the parties shall file a status report to describe their progress in settlement or narrowing the issues to be tried.