Opinion
12922-16 12923-16
10-06-2021
BRC Operating Company LLC, Bluescape Resource Company LLC, Tax Matters Partner, Et Al., Petitioner v. Commissioner of Internal Revenue, Respondent
ORDER
Cary Douglas Pugh Judge
On May 12, 2021, the Court issued a Memorandum Opinion (T.C. Memo. 2021-59) in these cases.
On June 22, 2021, petitioners filed a Motion for Leave to File Second Amended Petition, and lodged a Second Amended Petition, in docket no. 12923-16. On July 6, 2021, petitioners filed a Motion for Leave to File Second Amended Petition, and lodged a Second Amended Petition, in docket no. 12922-16.
On August 13, 2021, respondent filed a Response to Motion for Leave to File Second Amended Petition. On September 23, 2021, petitioners filed a Reply to Response to Motion for Leave to File Second Amended Petition. Upon due consideration it is hereby
ORDERED that petitioners' Motions for Leave to File Second Amended Petition, filed June 22, 2021, and July 6, 2021, are set for hearing at the Court's November 1, 2021, Miami, Florida trial session, schedule to commence at 10:00 am ET, to be conducted remotely. It is further
ORDERED that the Clerk of the Court shall also serve on the parties a Notice of Remote Proceeding that shall contain comprehensive instructions on how to participate in the Court's November 1, 2021, Miami, Florida trial session.
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