Opinion
30782-21
08-28-2023
JACKSON INVESTMENT GROUP, LLC, JIG RJ, INC., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Emin Toro, Judge.
This case is currently calendared for trial during the Court's September 18, 2023, Atlanta, Georgia, special trial session. By Order served June 8, 2023, this Court adopted the parties' proposed pretrial scheduling order as set forth in their joint Motion to Set Pretrial Scheduling Order, filed on June 2, 2023, with some modifications. In relevant part, the Order directed the parties that any responses to motions in limine shall be filed by the earlier of two weeks after the relevant motion is filed or September 11, 2023.
On August 25, 2023, petitioner filed a Motion to Shift the Burden of Proof on New Matters Raised by Respondent and Memorandum in Support (Doc. 90). On August 27, 2023, petitioner filed a Motion to Strike or Otherwise Exclude as Unreliable the Opinions, Reports, and Testimony of Respondent's Purported Expert Witness Todd P. Leavitt and Memorandum in Support (Doc. 93).
Upon due consideration, it is hereby
ORDERED that, on or before September 11, 2023, respondent shall file a response to petitioner's Motion to Shift the Burden of Proof on New Matters Raised by Respondent (Doc. 90). It is further
ORDERED that, on or before September 11, 2023, respondent shall file a response to petitioner's Motion to Strike or Otherwise Exclude as Unreliable the Opinions, Reports, and Testimony of Respondent's Purported Expert Witness Todd P. Leavitt (Doc. 93).