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Janicki v. Comm'r of Internal Revenue

United States Tax Court
Mar 10, 2023
No. 14367-21 (U.S.T.C. Mar. 10, 2023)

Opinion

14367-21 14370-21

03-10-2023

JOHN P. JANICKI & KATHERINE S. JANICKI, ET AL., Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent


ORDER

Ronald L. Buch Judge.

These cases were continued from the Court's March 27, 2023, St. Paul, Minnesota trial session and jurisdiction was retained by the undersigned. On March 3, 2023, the parties filed a joint status report informing the Court that they "have continued to work constructively and have come to an agreement on how to sequence discovery and dispositive motion practice so that the case can proceed in the manner most efficient for the Court and the Parties." They "agree to resolve the issue regarding the interpretation and application of Section 41(g) first by way of a motion for partial summary judgment." Accordingly, it is

ORDERED that Petitioners shall file their Motion for Partial Summary Judgment by May 12, 2023. It is further

ORDERED that the Commissioner shall file a Response to the Petitioners' Motion for Partial Summary Judgment by July 11, 2023. It is further

ORDERED that Petitioners shall file a Reply to the Commissioner's Response by August 10, 2023. It is further

ORDERED that all discovery is stayed until the motion for partial summary judgment is resolved.


Summaries of

Janicki v. Comm'r of Internal Revenue

United States Tax Court
Mar 10, 2023
No. 14367-21 (U.S.T.C. Mar. 10, 2023)
Case details for

Janicki v. Comm'r of Internal Revenue

Case Details

Full title:JOHN P. JANICKI & KATHERINE S. JANICKI, ET AL., Petitioners v…

Court:United States Tax Court

Date published: Mar 10, 2023

Citations

No. 14367-21 (U.S.T.C. Mar. 10, 2023)