Opinion
20397-21
07-12-2024
BROSIS PROPERTIES, LLC, BEAR CREEK LAND MANAGEMENT, 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 all agreed that it made sense to try to let petitioner meet with IRS Appeals to try to settle the case or at least narrow what needs to be tried. IRS Appeals then stopped work on it because of parallel criminal litigation. The parties reported earlier this year that Appeals recently reached out to petitioner to resume discussions, but the volume of conservation-easement cases seems to have stretched thin the AO's capacity.
The case can stay on a status-report track as long as settlement remains a possibility. The parties reasonably suggest reporting again in the fall if they haven't settled, and it is
ORDERED that on or before October 8, 2024 the parties submit decision documents or a file a joint status report in which they describe their progress toward settlement at IRS Appeals.