Jackson Inv. Grp. v. Comm'r of Internal Revenue

Full title: JACKSON INVESTMENT GROUP, LLC, JIG RJ, INC., TAX MATTERS PARTNER…

Court: United States Tax Court

Date published: Feb 13, 2023

No. 30782-21 (U.S.T.C. Feb. 13, 2023)

Opinion

30782-21

02-13-2023

JACKSON INVESTMENT GROUP, LLC, JIG RJ, INC., TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Emin Toro Judge

ORDER

Emin Toro Judge

This case is currently calendared for trial during the Court's March 6, 2023, Atlanta, Georgia, trial session. On January 13, 2023, respondent filed a Motion for Second Continuance of Trial (Doc. 22). On January 27, 2023, petitioner filed a Response in Opposition to Respondent's Second Motion for Continuance of Trial (Doc. 26).

On January 20, 2023, respondent filed a Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established pursuant to Rule 91(f), Tax Court Rules of Practice and Procedure (Doc. 24). Respondent requests that petitioner show cause why the facts and evidence set forth in respondent's proposed Stipulation of Facts marked as Exhibit A to respondent's motion together with exhibits should not be accepted as established for the purpose of this case. By Order served January 24, 2023, petitioner was directed to show cause on or before February 13, 2023, why paragraphs 1-271 in respondent's proposed stipulation of facts and evidence marked as Exhibit A together with the exhibits to respondent's Motion should not be deemed admitted for purposes of this case.

On February 9, 2023, the Court held a conference call with the parties to discuss, among other things, the current status of the case and the above-referenced pending motions. As discussed during the conference call and agreed to by the parties, the Court will continue this case and direct the parties to file a status report. The Court will hold in abeyance the Court's January 24, 2023, Order to Show Cause.

Upon due consideration, it is hereby

ORDERED that respondent's Motion for Second Continuance of Trial filed January 13, 2023, is granted in that this case is continued with jurisdiction retained by the undersigned judge. It is further

ORDERED that, on or before March 13, 2023, the parties shall file with the Court a joint status report (or, if that is not expedient, then separate reports) describing the status of the case or a stipulated decision document. The Status Report shall include a proposed scheduling order. It is further

ORDERED that the Court's January 24, 2023, Order to Show Cause is held in abeyance pending further Order of the Court.