Opinion
30782-21
09-07-2023
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. On August 15, 2023, respondent filed a Motion for Partial Summary Judgment (Doc. 82), along with a supporting Declaration (Doc. 83). On August 28, 2023, petitioner filed a Response in Opposition to Respondent's Motion for Partial Summary Judgment (Doc. 95), attaching a supporting Declaration.
The Court has carefully considered the parties' filings. Drawing factual inferences in favor of petitioner, see Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), aff 'd, 17 F.3d 965 (7th Cir. 1994), we find that there exists a genuine dispute as to material facts, see Rule 121(a), Tax Court Rules of Practice and Procedure.
Upon due consideration, it is hereby ORDERED that respondent's Motion for Partial Summary Judgment (Doc. 82) is denied.