Caneco Paetners, LLC v. Comm'r of Internal Revenue

Full title: CANECO PAETNERS, LLC, TUCKER KNOB, LLC, TAX MATTERS PARTNER, Petitioner v…

Court: United States Tax Court

Date published: Mar 24, 2022

No. 7431-19 (U.S.T.C. Mar. 24, 2022)

Opinion

7431-19

03-24-2022

CANECO PAETNERS, LLC, TUCKER KNOB, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Emin Toro, Judge

ORDER

Emin Toro, Judge

This case was assigned to the undersigned judge for trial or other disposition on February 14, 2020. On February 25, 2020, respondent filed a Motion for Partial Summary Judgment (Doc. 7) together with a Memorandum of Law in Support of Motion for Partial Summary Judgment (Doc. 8).

In an Order served February 4, 2022, the Court, among other things, directed petitioner to file a response to respondent's Motion for Partial Summary on or before February 11, 2022. The Order further directed respondent to file a reply, if any, to petitioner's response on or before March 14, 2022. By Order served February 11, 2022, petitioner's response deadline was extended to February 25, 2022, and respondent's reply deadline was extended to March 28, 2022.

On February 25, 2022, petitioner filed a Cross-Motion for Partial Summary Judgment and Incorporated Memorandum of Law (Doc. 35), Declaration of Gregory Rhodes in Support of Petitioner's Cross-Motion for Partial Summary Judgment and Opposition to Respondent's Motion for Partial Summary Judgment (Doc. 36), and Declaration of Robert D. Keller, Ph.D. (Doc. 37).

Later on February 25, 2022, petitioner filed a Response in Opposition to Respondent's Motion for Partial Summary Judgment (Doc. 38), along with a second Declaration of Gregory Rhodes in Support of Petitioner's Cross-Motion for Partial Summary Judgment and Opposition to Respondent's Motion for Partial Summary Judgment (Doc. 39) and Declaration of Robert D. Keller, Ph.D. (Doc. 40).

By Order served March 1, 2022, respondent was directed to file a response to petitioner's Cross-Motion for Partial Summary Judgment on or before March 30, 2022. By the same order, petitioner was directed to file a reply to respondent's response on or by April 29, 2022.

On March 21, 2022, respondent filed an unopposed Motion to Extend Time Within Which to File Response to Motion for Partial Summary Judgment (Doc. 42). Also on March 21, 2022, respondent filed an unopposed Motion to Extend Time Within Which to File Reply to Response to Motion for Partial Summary Judgment (Doc. 43).

Upon due consideration, it is hereby

ORDERED that respondent's Motion to Extend Time Within Which to File Reply to Response to Motion for Partial Summary Judgment is granted in that the time during which respondent shall file a reply to petitioner's response is extended from March 28, 2022, to April 15, 2022. It is further

ORDERED that respondent's Motion to Extend Time Within Which to File Response to Motion for Partial Summary Judgment is granted in that the time during which respondent shall file a response to petitioner's Cross-Motion for Partial Summary Judgment is extended from March 30, 2022, to April 15, 2022. It is further

ORDERED that the time during which petitioner may file a reply, if any, to respondent's response to petitioner's Cross-Motion for Partial Summary Judgment is extended from April 29, 2022, to May 23, 2022.