Opinion
17483-21
09-28-2022
ARDAN HOLDINGS, LLC, ARDAN INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes Judge
This case was on the Court's October 24, 2022 trial calendar for Atlanta, Georgia. It is one of many syndicated conservation-easement cases before the Court, and we continued it because the parties will need a considerable amount of discovery. They recently reported continued cooperation in informal discovery but with some technical glitches and a continued need to fulfill petitioner's FOIA disclosure request and a request to see the administrative file from the promulgation of the qualified-appraiser section of the regulations. This is progress, and the parties reasonably suggest reporting again in five months. It is therefore
ORDERED that on or before February 8, 2023 the parties shall file a status report to describe their progress informal discovery, particularly the status of petitioner's requests for the administrative file for the regulation, and respondent's progress in gathering his materials requested by petitioner under FOIA.