Opinion
8921-23
11-13-2024
1261 SUPERIOR, LLC, DIVERSIFIED HP 2014 INVESTORS LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda, Judge
On October 2, 2024, the Commissioner filed a motion for partial summary judgment [Doc. 20] and related attachments [Doc. 21]. On October 31, 2024, Petitioner filed a motion for extension of time to respond to Respondent's motion for partial summary judgment to which the Commissioner objected. [Doc. 23.] The Commissioner argued that Petitioner had not demonstrated good cause for a 30-day extension and that such an extension would prejudice the Commissioner. [Doc. 26.] The Commissioner stated that he would not oppose a 15-day extension, however. [Id.]
Petitioner filed a motion for leave to file a reply to the Commissioner's response. [Doc. 27.] In its reply, Petitioner asserts that the Commissioner's olive branch of 15 days does not provide sufficient relief. [Doc. 28.] Petitioner further represents that it would not object to an extension for filing a reply. [Id.] Upon due consideration, it is
ORDERED that Petitioner's motion for leave filed November 6, 2024, is granted. It is further
ORDERED that Petitioner's motion for extension of time filed October 31, 2024, is granted. It is further
ORDERED that the time in which Petitioner shall file a response to the Commissioner's motion for partial summary judgment is extended until December 15, 2024. It is further
ORDERED that the time in which the Commissioner shall file a reply to Petitioner's response to the motion for partial summary judgment is extended until February 18, 2025.