Opinion
12235-20 12249-20
12-21-2023
JACKSON CROSSROADS LLC, GREENCONE INVESTMENTS LLC, TAX MATTERS PARTNER, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler, Judge
These consolidated cases are scheduled for trial at a special session of the Court, commencing on January 8, 2024 in Atlanta, Georgia. On December 15, 2023, respondent filed a Motion in Limine to Exclude from Evidence the Report and Proposed Testimony of Nick Proctor and a Motion in Limine to Exclude from Evidence the Report and Proposed Testimony of David Bleakman. Also on December 15, 2023, respondent filed a Motion for Reconsider Order Granting in Part and Denying in Part Petitioner's Motion for Partial Summary Judgment.
On December 18, 2023, petitioner filed in these consolidated cases (i) a Motion in Limine to Exclude Testimony and Opinion Report by Andy D. Sheppard, (ii) a Motion to Exclude the Reports by Raymond H. Krasinski, (iii) a Motion to Exclude the Reports and Testimony of Berkley Tracy, (iv) a Motion in Limine to Exclude Congressional-Inducement-Motive and Other Data Either Wholly Irrelevant or Outweighed by Fed.R.Evid. 403 Considerations, and (v) a Motion in Limine to Shift the Burden of Proof to Respondent. Also, on December 18, 2023, respondent filed a Motion in Limine to Exclude from Evidence the Report and Proposed Testimony of Cody Hale.
Considering the foregoing, it is
ORDERED that on or before January 3, 2024, petitioner is to file a response in these cases to respondent's (i) Motion in Limine to Exclude from Evidence the Report and Proposed Testimony of Nick Proctor and (ii) Motion in Limine to Exclude from Evidence the Report and Proposed Testimony of David Bleakman, and (iii) Motion for Reconsider Order Granting in Part and Denying in Part Petitioner's Motion for Partial Summary Judgment. It is further
ORDERED that on before January 4, 2024, respondent is to file a response to petitioner's: (i) Motion in Limine to Exclude Testimony and Opinion Report by Andy D. Sheppard, (ii) Motion to Exclude the Reports by Raymond H. Krasinski, (iii) Motion to Exclude the Reports and Testimony of Berkley Tracy, (iv) Motion in Limine to Exclude Congressional-Inducement-Motive and Other Data Either Wholly Irrelevant or Outweighed by Fed.R.Evid. 403 Considerations, and (v) Motion in Limine to Shift the Burden of Proof to Respondent. It is further
ORDERED that on before January 4, 2024, petitioner is to file a response to respondent's Motion in Limine to Exclude from Evidence the Report and Proposed Testimony of Cody Hale.