Amgen Inc. v. Comm'r of Internal Revenue

Full title: AMGEN INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE…

Court: United States Tax Court

Date published: Nov 22, 2023

No. 16017-21 (U.S.T.C. Nov. 22, 2023)

Opinion

16017-21 15631-22

11-22-2023

AMGEN INC. & SUBSIDIARIES, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Travis A. Greaves, Judge.

ORDER

Travis A. Greaves, Judge.

Upon due consideration, it is

ORDERED that respondent's Motion to Seal, filed November 8, 2023, is granted in that respondent's Motion to Compel Production of Documents, filed November 8, 2023, shall be sealed from public view and shall not be inspected by any person or entity not a party to these cases, except by an Order of the Court. The Court taking into account Exhibits E and F attached to respondent's motion, it is further

ORDERED that petitioner shall, on or before December 27, 2023, file an objection, if any, or other response to respondent's Motion to Compel Production of Documents, filed November 8, 2023. It is further

ORDERED that the Declaration of Jenny Chang in Support of Memorandum in Support of Motion for Partial Summary Judgment, filed November 10, 2023, is recharacterized as the Declaration of Jenny Chang in Support of Motion for Partial Summary Judgment. It is further

ORDERED that petitioner's Motion for Summary Judgment, filed November 10, 2023, is recharacterized as petitioner's Motion for Partial Summary Judgment on HCR Fees Penalties. It is further

ORDERED that petitioner's Memorandum in Support of Petitioner's Motion for Summary Judgment, filed November 10, 2023, is recharacterized as petitioner's Memorandum in Support of Petitioner's Motion for Partial Summary Judgment on HCR Fees Penalties. It is further

ORDERED that the Declaration of Jenny Chang in Support of Memorandum in Support of Motion for Summary Judgment, filed November 10, 2023, is recharacterized as the Declaration of Jenny Chang in Support of Petitioner's Motion for Partial Summary Judgment on HCR Fees Penalties. It is further

ORDERED that petitioner's Motion to Seal, filed November 10, 2023, is granted in that (1) petitioner's Memorandum in Support of Petitioner's Motion for Partial Summary Judgment on HCR Fees Penalties, (2) Declaration of Jenny Chang in Support of Petitioner's Motion for Partial Summary Judgment on HCR Fees Penalties, and (3) Declaration of Jenny Chang in Support of Petitioner's Motion for Partial Summary Judgment, filed November 10, 2023, shall be sealed from public view and shall not be inspected by any person or entity not a party to these cases, except by an Order of the Court. It is further

ORDERED that respondent shall, on or before December 27, 2023, file an objection, if any, or other response to petitioner's (1) Motion for Partial Summary Judgment and (2) Motion for Partial Summary Judgment on HCR Fees Penalties, filed November 10, 2023.