Opinion
17076-21
03-21-2023
J L MINERALS, LLC, BEASLEY TIMBER MANAGEMENT, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge
This case was tried at the Court's Special Session in Atlanta, Georgia, which began on February 27, 2023. Both parties appeared and were heard. Upon due consideration, and for cause more fully appearing in the transcript of the proceedings, it is
ORDERED that the Commissioner's motion for leave to file Volume 1: Technical Geologic and Exploration Expert Opinion Report of Dr. Bart Stryhas (Doc. 170), filed January 31, 2023, is granted in that the lodged expert report at Doc. 171 is filed as Volume 1: Technical Geologic and Exploration Expert Opinion Report of Dr. Bart Stryhas (Exhibit 501-R), as of the service date of this Order. It is further
ORDERED that the Commissioner's motion for leave to file expert prospective appraisal report by Andy Shepperd (Doc. 172), filed January 31, 2023, is granted in that the lodged expert report at Doc. 173 is filed as Expert Prospective Appraisal Report by Andy Shepperd (Exhibit 506-R), as of the service date of this Order. It is further
ORDERED that the Commissioner's motion for leave to file expert wildlife ecology and conservation report by Dr. Martin Main, PhD (Doc. 174), filed January 31, 2023, is granted in that the lodged expert report at Doc. 175 is filed as Expert Wildlife Ecology and Conservation Report by Dr. Martin Main, PhD (Exhibit 500-R), as of the service date of this Order. It is further
ORDERED that the Commissioner's motion for leave to file Volume 2: Technical Export Report on JL-65 Mineral Resource Estimation of Dr. Bart Stryhas (Doc. 177), filed January 31, 2023, is granted in that the lodged expert report at Doc. 178 is filed as Volume 2: Technical Expert Report on JL-65 Mineral Resource Estimation of Dr. Bart Stryhas (Exhibit 502-R), as of the service date of this Order. It is further
ORDERED that the Commissioner's motion for leave to file Volume 3: Technical Mining Expert Opinion Report of Dr. Silver Miller, Ph.D. (Doc. 179), filed January 31, 2023, is granted in that the lodged expert report at Doc. 180 is filed as Volume 3: Technical Mining Expert Opinion Report of Dr. Silver Miller (Exhibit 503-R), as of the service date of this Order. It is further
ORDERED that the Commissioner's motion for leave to file expert USPAP Compliance Review Report by Raymond Krasinski (Doc. 182), filed January 31, 2023, is granted in that the lodged expert report at Doc. 183 is filed as Expert USPAP Compliance Review Report by Raymond Krasinski (Exhibit 505-R), as of the service date of this Order. It is further
ORDERED that the Commissioner's motion for leave to file Volume 4: Technical Expert Opinion Report of Matthew Sullivan (Doc. 184), filed January 31, 2023, is granted in that the lodged expert report at Doc. 185 is filed as Volume 4: Technical Expert Opinion Report of Matthew Sullivan (Exhibit 504-R), as of the service date of this Order. It is further
ORDERED that the Commissioner's motion for leave to file Matthew Sullivan's Expert Rebuttal Report of Capps Geoscience, LLC, Resource Valuation Report (Doc. 210), filed February 9, 2023, is granted in that the lodged expert rebuttal report at Doc. 211 is filed as Matthew Sullivan's Expert Rebuttal Report of Capps Geoscience, LLC Resource Valuation Report (Exhibit 507-R), as of the service date of this Order. It is further
ORDERED that the Commissioner's motion for leave to file Dr. Bart Stryhas's Technical Expert Rebuttal Report of Geologic's Geological and Mining Evaluation Report (Doc. 212), filed February 9, 2023, is granted in that the lodged expert rebuttal report at Doc. 213 is filed as Dr. Bart Stryhas's Technical Expert Rebuttal Report of Geologic's Geological and Mining Evaluation Report (Exhibit 508-R), as of the service date of this Order. It is further
ORDERED that the Commissioner's motion for leave to file Technical Appraisal Review Expert Rebuttal Report of Expert Appraisal Reports Filed by Dale W. Hayter, Thomas G. Spears, and Douglas R. Kenny (Doc. 214), filed February 9, 2023, is granted in that the lodged expert rebuttal report at Doc. 215 is filed as Technical Appraisal Review Expert Rebuttal Report of Expert Appraisal Reports Filed by Dale W. Hayter, Thomas G. Spears, and Douglas R. Kenny by Andrew Sheppard (Exhibit 509-R), as of the service date of this Order.