Opinion
25760-17
09-20-2021
Gramercy Financial Group LLC, Cerro Negro Capital Management, LLC, Tax Matters Partner Petitioner v. Commissioner of Internal Revenue Respondent
ORDER
David Gustafson Judge
On September 13, 2021, the Commissioner filed a motion for entry of decision under Rule 248(b) of the Tax Court Rules of Practice and Procedure. Rule 248(b) requires that the Tax Matters Partner notify all other parties (i.e., partners) of the the Commissioner's motion and that the Court allow 60 days for any party to intervene in this proceeding and object to entry of the proposed decision. If no one intervenes, then the Court may enter the proposed decision. It is therefore
ORDERED that the Court's order of September 24, 2020, requiring the parties to file periodic status reports every 90 days is hereby vacated, and that the parties are no longer required to file periodic status reports. It is further
ORDERED that the Commissioner's second-filed motion (Doc. 53) is duplicative of the first filed motion (at Doc. 52), and is hereby stricken from the record in this case. It is further
ORDERED that, on or before November 19, 2021, 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.
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