Opinion
5114-19 13634-19 14053-19 14462-19 14464-19
04-26-2023
ANDRE TEMNOROD & BRIANNA TEMNOROD, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth A. Copeland Judge
These consolidated cases were heard for trial at the Trial Session of the Court in Cleveland, Ohio beginning on April 18, 2023, for two days in person, and concluding remotely on April 21, 2023.
On March 16, 2023 (in Docket No. 5114-19) and April 26, 2023, (in Docket Nos. 13634-19, 14053-19, 14462-19, 14464-19), petitioners filed with the Court an Expert Report of Carey Roesel. On April 7, 2023, respondent filed with the Court a Motion in Limine. During trial, the Court ruled on the Motion in Limine, which was granted in part and denied in part.
Upon due consideration, and for cause more fully appearing in the transcript of these proceedings, it is
ORDERED that respondent's Motion in Limine, filed with the Court on April 7, 2023, is hereby granted in part in that Paragraph 2.B.19. is not admitted as part of the Expert Report of Carey Roesel and shall not be considered as a valuation of the Infotelecom LLC ICAs at issue during the 2012 tax year. Respondent's Motion in Limine is otherwise denied.