Opinion
6981-19
03-08-2023
GWA, LLC, GEORGE A. WEISS, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
This case was tried at a two-week special session in Washington, D.C., from September 12 to 23, 2022. At the conclusion of the trial, the Court indicated that the record would be left open until November 22, 2022, to permit the parties to file additional stipulations of facts and exhibits. Because of complications in filing the proposed Twelfth Stipulation of Facts, we later extended that deadline to March 3, 2023.
On February 27, 2023, the parties filed, at docket entries ## 313-318, Exhibits 1054-J through 1063-J to the Seventh Stipulation of Facts, which was admitted into evidence by Order served December 30, 2022. On February 28, 2023, the parties filed, at docket entry # 319, Exhibit 1006-J-C to the Eleventh Stipulation of Facts, which was submitted via USB drive during trial on September 23, 2022, to be filed under seal. On February 28, and March 1, 2023, the parties also filed, at docket entries ## 320-327, a Twelfth Stipulation of Facts and Exhibits thereto. We will admit all of these items into evidence and close the record at long last.
Upon due consideration, it is
ORDERED that docket entries ## 313-318, consisting of Exhibits 1054-J through 1063-J to the Seventh Stipulation of Facts, are admitted into evidence and made part of the record. It is further
ORDERED that the Eleventh Stipulation of Facts and accompanying Exhibit 1006-J-C, filed at docket entry #319, are admitted into evidence but are sealed and not made part of the Court's public record in this case. It is further
ORDERED that the Twelfth Stipulation of Facts and accompanying Exhibits, filed at docket entries ## 320-327, are admitted into evidence and made part of the record. It is further
ORDERED that the record in this case is closed, and the Court will decide the case on the basis of the entire record.