Opinion
10588-16
10-14-2022
WOODLAND PROPERTY HOLDINGS, LLC, WOODLAND LAND MANAGER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber, Judge
Woodland Land Manager, LLC, the petitioner in this case, is the tax matters partner (TMP) of Woodland Property Holdings, LLC (Woodland). On July 27, 2022, the parties filed a joint status report representing that they reached a settlement of all the issues in this case. In that report, the parties represented that 36 of Woodland's 39 partners had accepted the settlement. On October 3, 2022, respondent filed a Motion for Entry of Decision to which petitioner did not object.
Rule 248(b) requires that the TMP notify nonparticipating partners of the Commissioner's motion and that the Court allow 60 days for any partner to elect to intervene in this proceeding and object to entry of the proposed decision. If no partner intervenes, then the Court may enter the proposed decision. In consideration of the foregoing, it is
ORDERED that, on or before December 12, 2022, any party who objects to the granting of respondent's Motion for Entry of Decision shall file (1) a motion for leave to file a notice of election to participate out of time and (2) a notice of election to participate. It is further
ORDERED that, in addition to regular service, the Clerk of the Court shall serve a copy of this Order on the TMP at the following addresses:
Woodland Land Manager, LLC Tax Matters Partner of Woodland Property Holdings, LLC c/o Dwayne P. (Pete) Davis 34 Old Ivy Road, Suite 200 Atlanta, Georgia 30342
Woodland Land Manager, LLC Tax Matters Partner of Woodland Property Holdings, LLC c/o Dwayne P. (Pete) Davis 38 Old Ivy Road, Suite 200 Atlanta, Georgia 30342