Opinion
5191-20
08-25-2022
CORY H. SMITH, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro, Judge
Pursuant to the determination of the Court as set forth in its Opinion (159 T.C. No. 3), filed August 25, 2022, it is hereby
ORDERED that respondent's Motion for Partial Summary Judgment (Doc. 39) is granted. It is further
ORDERED that petitioner's Motion for Partial Summary Judgment (Doc. 40) is denied. It is further
ORDERED that petitioner's Motion for Leave to File Expert Report (Doc. 24), as amended on April 22, 2022 (Doc. 51) is granted in that the Expert Report of Terry Dwyer (Doc. 25) lodged on February 7, 2022, shall remain lodged and the Expert Report of Terry Dwyer (Doc. 52) lodged on April 22, 2022, is filed as of the date of this Order. It is further
ORDERED that respondent's Motion in Limine to Exclude the Testimony and Expert Report of Petitioner's Proposed Expert Witness Terry Dwyer (Doc. 63) is denied. It is further
ORDERED that, on or before September 26, 2022, the parties shall file a joint report with the Court (or, if that is not expedient, then separate reports) describing the status of the case and recommending appropriate future proceedings.