Opinion
5071-21
06-16-2023
SEABROOK PROPERTY, LLC, SEABROOK MANAGER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro Judge
This case is currently calendared for trial during the Court's June 26, 2023, Jacksonville, Florida, special trial session. On June 13, 2023, the parties filed a Joint Motion for Pretrial Conference (Doc. 110). The Court and the parties have identified issues that may benefit from a Pretrial Conference with the Court. In addition to the matters raised by the parties in their Joint Motion, the parties should come prepared to discuss the Court's recent decisions in Murphy v. Commissioner, T.C. Memo. 2023-72 and Murfam Enterprises LLC v. Commissioner, T.C. Memo. 2023-73, as they relate to the issues in dispute in this case. Upon due consideration, it is hereby
ORDERED that the parties' Joint Motion for Pretrial Conference filed June 13, 2023, is granted in that this case set for hearing at a remote Special Session scheduled to commence on Thursday, June 22, 2023, at 9:00 a.m. (Eastern Time). Jacksonville, Florida, shall be listed as the place of trial for this remote session. It is further
ORDERED that the Clerk of the Court shall issue a Notice of Remote Proceeding to the parties that shall contain comprehensive instructions on how to participate in the above-referenced remote proceeding.