Opinion
13013-20
06-13-2023
DESOTO HOLDINGS LLC, DESOTO INVESTORS LLC, TAX MATTERS PARTNER, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris, Judge
This case was previously calendared for trial at the Court's February 13, 2023, Atlanta, Georgia Trial Session and by Joint Motion for Continuance, this case was continued with jurisdiction retained by this Division of the Court, by Order dated January 9, 2023, docket entry 29.
On March 1, 2023, the parties filed a First Stipulation of Facts, consisting of paragraphs 1 through 42, at docket entry 30, with attached Exhibits 1-J - 24-J, at docket entry 31.
On April 26, 2023, respondent filed (1) a Motion for Partial Summary Judgment; and (2) a Declaration of John B. Siegmund in Support of Motion for Partial Summary Judgment, docket entries 35 and 36 respectively.
Respondent's Motion for Partial Summary Judgment requests for partial summary judgment in respondent's favor in the above-captioned case upon the issue of whether respondent complied with the requirements of section 6751(b)(1) as applied to the penalties at issue in this case. Respondent's Motion indicates that petitioner objects to the granting of this motion.
After due consideration, and for cause, it is
ORDERED that, on or before July 10, 2023, petitioner shall file a response to respondent's Motion for Partial Summary Judgment, filed April 26, 2023, docket entry 35.