Opinion
16536-23
11-04-2024
CAPITOL PLACES II OWNER, LLC, HISTORIC PRESERVATION FUND 2014 LLC, A PARTNER OTHER THAN THE TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
On November 3, 2024, Petitioner filed a motion to determine that Respondent's qualified appraisal and appraiser issue is a new matter [Doc. 41]. We will direct the Commissioner to file a response to this motion and allow the Petitioner to file a reply to that response. Accordingly, it is
ORDERED that, on or before November 26, 2024, the Commissioner shall file a response to the Petitioner's motion to determine that Respondent's qualified appraisal and appraiser issue is a new matter filed November 3, 2024. It is further
ORDERED that on or before December 10, 2024, the Petitioner shall file a reply to the Commissioner's response to the motion to determine that Respondent's qualified appraisal and appraiser issue is a new matter.