Opinion
30287-21
12-20-2023
SYDNEY ROADS, LLC, SYDNEY ROADS INVESTMENTS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Cary Douglas Pugh Judge
On December 19, 2023, petitioner filed a Motion for Reconsideration of Order, a Memorandum in Support of Motion for Reconsideration of Order, a Declaration of David Wooldridge in Support of Motion for Reconsideration of Order, and a Motion to Seal those documents. Upon due consideration and for cause, it is hereby
ORDERED that petitioner's Motion for Reconsideration of Order, Memorandum in Support of Motion for Reconsideration of Order, and Declaration of David Wooldridge in Support of Motion for Reconsideration of Order are temporarily sealed pending the disposition of petitioner's Motion to Seal. It is further
ORDERED that, on or before January 10, 2024, respondent shall file separate responses to petitioner's Motion for Reconsideration of Order and petitioner's Motion to Seal.