Opinion
24997-21
08-03-2023
CAPITAL SHIP, LLC, LLH INVESTMENT FUND II, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge
This case was previously calendared for trial at the Court's January 30, 2023, Birmingham, Alabama Trial Session and by Joint Motion for Continuance, this case was continued with jurisdiction retained by this Division of the Court, by Order dated October 28, 2022, docket entry 12.
On October 1, 2021, docket entry 1, petitioner filed a petition with this Court to review a Notice of Final Partnership Administrative Adjustments that (1) disallowed a charitable contribution of a donation of a conservation easement; and (2) determined penalties.
On May 3, 2023, respondent filed (1) a Motion to Compel Responses to Interrogatories, docket entry 23; and (2) a Motion to Compel Production of Documents, docket entry 24.
On July 24, 2023, petitioner filed (1) a Response to Motion to Compel Production of Documents, docket entry 30; (2) a Declaration of Sidney W. Jackson, IV in Support of Response to Motion to Compel Production of Documents, docket entry 31; (3) a Response to Motion to Compel Responses to Interrogatories, docket entry 32; and (4) a Declaration of Sidney W Jackson, IV in Support of Response to Motion to Compel Responses to Interrogatories, docket entry 33.
After due consideration, and for cause, it is
ORDERED that, on or before August 22, 2023, respondent shall file a reply to petitioner's Responses and Declarations, filed July 24, 2023, docket entries 30, 31, 32, and 33 respectively.