Opinion
14870-20 14875-20
06-01-2023
MICHAEL DAVIS & AMY L. DAVIS, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler, Judge.
On May 25, 2023, respondent filed his Second Motion for Partial Summary Judgment, along with a memorandum of law in support and Declarations by Kimberly Tyson, Carol Hassell, Clark Wong, and George Petkovich. Respondent seeks a favorable ruling from this Court on whether petitioner's appraisal attached to its tax return was materially deficient and fails as a "qualified appraisal" under the Section 170(f) and generally accepted appraisal standards. On May 26, 2023, respondent also filed a Motion to Strike the incomplete affidavit of Carol Hassell (Doc. 63 in Docket No. 14570-20 and Doc. 60 in Docket No. 14875-20), in these consolidated matters.
Considering the foregoing, it is
ORDERED that petitioners shall file on or before June 13, 2023, a response to respondent's Second Motion for Partial Summary Judgment and Motion to Strike in these consolidated matters.