Opinion
12271-20 12274-20
02-09-2023
JACKSON STONE SOUTH, LLC, JACKSON SOUTH INVESTMENTS, LLC, TAX MATTERS PARTNER, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Alina I. Marshall Judge
These consolidated cases are calendared for an in-person trial at a special session of the Court scheduled to commence on March 13, 2023, in Washington, D.C.
On January 27, 2023, respondent filed various documents titled "Proposed Trial Exhibits". On the same date, petitioners filed various documents titled "Proposed Trial Exhibits". Upon review of the parties' respective filings, the Court concludes that those documents are in fact proposed expert witness reports.
The Court directs the parties to adhere to the procedures for filing expert witness reports as set forth in the Court's standing pretrial order issued January 10, 2022. In addition, the Court directs the parties to file the motions for leave to file expert reports in both consolidated cases.
Accordingly, it is
ORDERED that respondent's documents titled "Proposed Trial Exhibits" filed January 27, 2023, in the case at docket No. 12271-20 at docket index Nos. 61, 62, 63, and 64, are hereby stricken from the record. It is further
ORDERED that petitioners' documents titled "Proposed Trial Exhibits" filed January 27, 2023, in the case at docket No. 12271-20 at docket index Nos. 65, 66, 67, 68, 69, 70, and 71, are herby stricken from the record. It is further
ORDERED that respondent's documents titled "Proposed Trial Exhibits" filed January 27, 2023, in the case at docket No. 12274-20 at docket index Nos. 59, 60, 61, 62, and 63, are hereby stricken from the record. It is further
ORDERED that petitioners' documents titled "Proposed Trial Exhibits" filed January 27, 2023, in the case at docket No. 12274-20 at docket index Nos. 64, 65, 66, 67, 68, 69, and 70, are hereby stricken from the record. It is further
ORDERED that the parties are directed to file the motions for leave to file expert witness reports in both of the consolidated cases.