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Big Sky Propco, LLC v. Comm'r of Internal Revenue

United States Tax Court
Mar 6, 2023
No. 5210-21 (U.S.T.C. Mar. 6, 2023)

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.


Summaries of

Big Sky Propco, LLC v. Comm'r of Internal Revenue

United States Tax Court
Mar 6, 2023
No. 5210-21 (U.S.T.C. Mar. 6, 2023)
Case details for

Big Sky Propco, LLC v. Comm'r of Internal Revenue

Case Details

Full title:BIG SKY PROPCO, LLC, BIG SKY MANAGER, LLC, TAX MATTERS PARTNER, Petitioner…

Court:United States Tax Court

Date published: Mar 6, 2023

Citations

No. 5210-21 (U.S.T.C. Mar. 6, 2023)