Opinion
30791-21
09-29-2022
GREEN COVE ROCK, LLC, GH MANAGER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Kathleen Kerrigan, Chief Judge.
On May 20, 2022, respondent filed a Motion for Partial Summary Judgment. By Order Served June 9, 2022, the Court directed petitioner to file a Response to respondent's motion on or before June 30, 2022. To date, petitioner has filed three motions for extension of time to file petitioner's response, which the Court has granted. Petitioner's Response to respondent's motion is currently due on or before October 3, 2022. On September 13, 2022, the Court of Appeals for the Eleventh Circuit issued an opinion in Kroner v. Commissioner, No. 20-13902 (11th Cir. Sep. 13, 2022), rev'g in part T.C. Memo. 2020-73.
Upon due consideration, it is
ORDERED that, on or before October 20, 2022, respondent shall file a Supplement to his Motion for Partial Summary Judgment, addressing the applicability, if any, of the Eleventh Circuit's decision in Kroner v. Commissioner to his motion. It is further
ORDERED that the time within which petitioner shall file a Response to respondent's Motion for Partial Summary Judgment, as supplemented, is extended to November 10, 2022. It is further
ORDERED that this case is assigned to Judge Joseph R. Goeke for trial or other disposition.