Opinion
5210-21
03-06-2023
BIG SKY PROPCO, LLC, BIG SKY MANAGER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda, Judge.
On February 27, 2023, the Commissioner filed motion for partial summary judgment upon the issue of whether he timely approved various penalties under I.R.C. § 6751(b) and also filed a supporting declaration. [Docs. 26 & 27] We will direct petitioner Big Sky Propco, LLC, Big Sky Manager, LLC, Tax Matters Partner (Big Sky) to file a response and the Commissioner to file a reply.
Accordingly, it is
ORDERED that, on or before March 30, 2023, Big Sky shall file a response to the Commissioner's motion for partial summary judgment. It is further
ORDERED that, on or before April 20, 2023, the Commissioner shall file a reply to the Commissioner's response to the motion for partial summary judgment.