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

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

Court: United States Tax Court

Date published: Apr 20, 2022

No. 7431-19 (U.S.T.C. Apr. 20, 2022)

Opinion

7431-19

04-20-2022

CANECO PARTNERS, 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). On February 25, 2022, petitioner filed a Response in Opposition to Respondent's Motion for Partial Summary Judgment (Doc. 38). On April 15, 2022, respondent filed a Reply to Petitioner's Response to Respondent's Motion for Partial Summary Judgment (Doc. 45).

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 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).

On April 15, 2022, respondent filed an Objection to Petitioner's Motion for Partial Summary Judgment (Doc. 46).

By Order served March 24, 2022, the Court, among other things, extended the time during which petitioner may file a reply, if any, to respondent's response to petitioner's Cross-Motion for Partial Summary Judgment from April 29, 2022, to May 23, 2022.

On April 15, 2022, respondent filed a Supplement to Motion for Partial Summary Judgment (Doc. 47) together with a Supplement to Memorandum of Law in Support of Motion for Partial Summary Judgment (Doc. 48).

Upon due consideration, it is hereby

ORDERED that, on or before May 23, 2022, petitioner shall file a response to respondent's Motion for Summary Judgment as supplemented. It is further

ORDERED that, on or before June 7, 2022, respondent shall file a reply, if any, to petitioner's response.