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.