Opinion
10383-23
07-01-2024
JEFFERSON PROPERTY HOLDINGS, LLC, STRATEGIC FUND MANAGER, LLC PARTNERSHIP REPRESENTATIVE, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber, Judge.
On June 25, 2024, this case was assigned to the undersigned for trial or other disposition. The case involves a charitable contribution deduction claimed by Jefferson Property Holdings, LLC, for a conservation easement in 2018.
On June 7, 2024, petitioner filed a Motion for Partial Summary Judgment at docket entry #18. Petitioner's Motion contends that I.R.C. §§ 724(b) and 170(e) do not apply as a matter of law to this case. Petitioner contends that there exist no disputes of material fact regarding these issues, that trial of these issues is not necessary, and that petitioner is entitled to judgment as a matter of law.
We will request a response to the Motion. To the extent respondent believes that the proper disposition of the legal issues presented by the Motion is controlled by prior decisions of this Court, it will be sufficient for respondent to point the Court to the relevant portions of the relevant Opinions, together with whatever additional argument he believes necessary.
In consideration of the foregoing, it is
ORDERED that, on or before July 31, 2024, respondent shall file a Response to petitioner's Motion for Partial Summary Judgment, filed June 7, 2024, at docket entry #18.