Opinion
4823-21
11-22-2022
COMPUTER SCIENCES CORPORATION, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro, Judge.
This deficiency case involves, among other things, a question about the tax consequences of petitioner's sale to an unrelated party of an instrument styled as Participating Class A Stock issued by one of petitioner's subsidiaries.
In reviewing the parties' most recent submissions, the undersigned judge became aware that the purchaser of the instrument was represented in the transaction by Covington & Burling LLP, at a time when the undersigned judge was a partner of that firm. The parties' submissions suggest that the Court may be required to address, among others, discovery disputes that may involve the purchaser of the instrument and its counsel.
In view of the foregoing, the undersigned judge will remove himself from the case. Cf. In re Rogers, 537 F.2d 1196 (4th Cir. 1976). Upon due consideration, it is hereby
ORDERED that the undersigned judge no longer retains jurisdiction and is recused from further work on this case.