Opinion
32146-21
07-09-2024
EMERALD RESOURCES, LLC, GH MANAGER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
On July 8, 2024, the Commissioner filed a motion for entry of decision stating that the parties have reached a basis of settlement. The Commissioner's motion represents that GH Manager, LLC as the Tax Matters Partner for Emerald Resources, LLC agrees to the entry of the proposed stipulated decision, but does not certify that no party objects to the granting of the motion for entry of decision.
Rule 248(b), Tax Court Rules of Practice and Procedure, requires that the tax matters partner notify nonparticipating partners of the Commissioner's motion and that the Court allow 60 days for any partner to elect to intervene and object to entry of the proposed decision. If no partner intervenes, then the Court may enter the proposed decision. In consideration of the foregoing, it is
ORDERED that on or before September 6, 2024, any party who objects to the granting of the Commissioner's motion for entry of decision shall file (1) a motion for leave to file a notice of election to participate out of time and (2) a notice of election to participate.