Opinion
4868-15
03-28-2023
CHAMPIONS RETREAT GOLF FOUNDERS, LLC., RIVERWOOD LAND, LLC., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Cary Douglas Pugh Judge
On October 17, 2022, the Court issued its Memorandum Opinion (T.C. Memo. 2022-106), and decision is to be entered under Rule 155, Tax Court Rules of Practice and Procedure. The parties' Rule 155 computations are due April 11, 2023. On March 20, 2023, petitioner filed a Motion for Reasonable Litigation or Administrative Costs and a Memorandum in Support of Motion for Reasonable Litigation or Administrative Costs. On March 22, 2023, petitioner filed a First Amended Motion for Reasonable Litigation or Administrative Costs. Upon due consideration and for cause, it is hereby
ORDERED that petitioner's Memorandum in Support of Motion for Reasonable Litigation or Administrative Costs is recharacterized as petitioner's "Memorandum in Support of First Amended Motion for Reasonable Litigation or Administrative Costs". It is further
ORDERED that, on or before April 24, 2023, respondent shall file a response to petitioner's First Amended Motion for Reasonable Litigation or Administrative Costs, filed March 22, 2023.