Opinion
12428-20
03-27-2023
CORNING PLACE OHIO, LLC, CORNING PLACE OHIO INVESTMENT, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
This case was tried at a three-day special session in Cleveland, Ohio, from March 21 to 23, 2023. During the trial respondent brought forth evidence in the form of two voice messages attached to emails and played them for the Court. Because the voice messages did not constitute trial testimony, they were not recorded by the Court Reporter and will not appear in the transcript of the trial. Respondent indicated that he would make transcripts of the voice messages and seek agreement from petitioner on the accuracy of the transcripts. The Court expressed its understanding that the transcripts of the two voice messages would then be attached as exhibits to a forthcoming final stipulation of facts.
Upon due consideration and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that the record shall remain open for another 30 days, until April 24, 2023, to permit the submission of a forthcoming stipulation of facts with attached exhibits.