Opinion
16284-21
07-22-2024
ALBERO HOLDINGS, LLC, ALBERO INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris, Judge
On December 1, 2023, docket entry 37, respondent filed a Motion for Partial Summary Judgment moving for summary adjudication in respondent's favor upon the issue of whether respondent satisfied the written supervisory approval requirement of Internal Revenue Code section 6751(b) in this case.
On May 21, 2024, docket entry 73, petitioner filed an Opposition to Respondent's Motion for Partial Summary Judgment.
After due consideration, it is
ORDERED that, on or before August 13, 2024, respondent shall file with the Court a response to petitioner's Opposition to Respondent's Motion for Partial Summary Judgment, filed May 21, 2024, docket entry 73.