Opinion
20608-18 7097-19 7703-19
03-21-2023
EXCELSIOR AGGREGATES, LLC, BIG ESCAMBIA VENTURES, LLC, TAX MATTERS PARTNER, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber, Judge.
These cases were tried from December 5 to 15, 2022, in Atlanta, Georgia. On March 14, 2023, petitioners electronically filed a Motion to Change or Correct Docket Entry. Petitioners indicated that their Simultaneous Opening Brief, filed on March 14, 2023, at docket entry # 418, contains two errors on page 191. Petitioners seek to substitute a corrected version of this page for the incorrect version in the original filing. Petitioners appended to their Motion exhibits containing a corrected version of page 191 and a complete copy of an amended Simultaneous Opening Brief incorporating the corrected version of page 191. Unfortunately, the Court is unable to substitute pages in electronically filed documents or to detach an exhibit and file it separately. We will thus ask petitioners to file an Amended Simultaneous Opening Brief.
All references to docket entries in this Order are to docket entries in the lead case, Excelsior Aggregates, LLC v. Commissioner, No. 20608-18.
Upon due consideration and for cause, it is
ORDERED that petitioners' above-referenced Motion is granted in that, on or before March 31, 2023, petitioners shall file an Amended Simultaneous Opening Brief in its entirety, incorporating the corrected version of the page referenced in the Motion.