Opinion
16284-21
06-07-2024
ALBERO HOLDINGS, LLC, ALBERO INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge
This case is calendared for trial at a one-week in-person Special Trial Session of the Court on May 12, 2025, in Atlanta, Georgia.
On October 31, 2023, respondent filed a Motion for Document Subpoena Hearing requesting that the Court issue an order scheduling a remote hearing to address and provide a return date for supoenas that respondent intended to issue in this case. Respondent indicated that he intended to issue several third-party subpoenas to potential witnesses.
On March 15, 2024, docket entry 52, petitioner filed an Objection to Motion for Document Subpoena Hearing.
On March 27, 2024, docket entry 58, after a hearing was held on March 25, 2024, the Court granted respondent's Motion for Document Subpoena Hearing filed October 31, 2023, docket entry 36, and scheduled this case for a hearing on Wednesday, June 26, 2024, Washington DC, special hearing session to be conducted remotely at which any third-party subpoenas may be returnable. Additionally, the Court ordered respondent, on or before June 20, 2024, to file a status report advising the Court whether the third parties have complied with the subpoenas and a hearing is no longer necessary.
It appears that as of June 7, 2024, respondent has noticed over ninety subpoenas.
After due consideration, it is
ORDERED that, on or before June 14, 2024, respondent shall file a preliminary status report advising the Court whether the subpoena recipients have complied with the subpoenas. This preliminary status report is in addition to the status report due on or before June 20, 2024.