Opinion
26172-21
01-30-2023
ALLIGATOR HOLDINGS, LLC, AMERICAN DIVERSIFIED DEVELOPMENT, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge
On January 25, 2023, docket entry 15, the parties filed a Joint Status Report indicating that this case is related to two other docketed cases that may share legal and factual issues: (1) Polk Quarries, LLC, Polk Limestone Investors, LLC, Tax Matters Partner v. Commissioner, Docket No. 23531-21; and (2) Capital Ship, LLC, LLH Investment Fund II, LLC, Tax Matters Partner v. Commissioner, Docket No. 24997-21. Further, a priority for the parties is determining a way to efficiently prepare and try these related cases, including whether the parties can agree on a test case. This case has been referred to the IRS Independent Office of Appeals to see if a settlement can be reached. The parties are currently engaged in discovery.
After due consideration, and for cause, it is
ORDERED that, on or before May 1, 2023, the parties shall file Joint Status Reports with the Court as to the then-present status of this case.