Opinion
26172-21
03-27-2024
ALLIGATOR HOLDINGS, LLC, AMERICAN DIVERSIFIED DEVELOPMENT, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge
On May 4, 2023, respondent filed a Motion to Compel Responses to Interrogatories and a Motion to Compel Production of Documents, at docket entries 18 and 19. On July 24, 2023, docket entry 25, petitioner filed a Response to Motion to Compel Responses to Interrogatories, and at docket entry 27, petitioner filed a Response to Motion to Compel Production of Documents. On August 22, 2023, respondent filed a Reply to Response to Motion to Compel Responses to Interrogatories, and Reply to Response to Motion to Compel Production of Documents, at docket entries 34 and 35.
By Order dated March 5, 2024, docket entry 39, the Court set respondent's Motion to Compel Responses to Interrogatories and Motion to Compel Production of Documents filed May 4, 2023, docket entries 18 and 19, for Hearing at the Court's March 25, 2024, Washington, D.C., remote Special Trial Session of the Court. On March 26, 2024, docket entry 45, the parties filed a Joint Status Report.
This case was called for Hearing on March 26, 2024, at the Court's March 25, 2024, Washington, D.C., remote Special Trial Session of the Court. The parties appeared and were heard.
After due consideration, and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that respondent's Motion to Compel Responses to Interrogatories, filed May 4, 2023, docket entry 18, is granted in that, on or before May 31, 2024, the petitioner shall complete the actions and timelines more fully described as agreed to in the Joint Status Report filed with the Court on March 26, 2024, docket entry 45; and, reported by the parties to the Court at this hearing. It is further
ORDERED that respondent's Motion to Compel Production of Documents filed May 4, 2023, docket entry 19, is granted in that, on or before May 31, 2024, the petitioner shall complete the actions and timelines more fully described as agreed to in the Joint Status Report filed with the Court on March 26, 2024, docket entry 45; and, reported by the parties to the Court at this hearing are incorporated by reference in this Order. It is further
ORDERED that, on or before May 31, 2024, the parties shall file with the Court a status report (jointly, if possible, otherwise separately) detailing the then-present status of the case. It is further
ORDERED that, on or before May 31, 2024, the parties shall file a Joint Stipulation of Facts with the Court to establish basic jurisdictional facts.