Opinion
13925-17
05-25-2023
LAKEPOINT LAND II, LLC, LAKEPOINT LAND GROUP, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge.
On May 15, 2023, petitioner filed a Motion to Set for a Time & Date Certain, wherein it moves that the Court schedule an evidentiary hearing to receive evidence and testimony and argument on three pending motions (pending motions) relating to the Court's March 24, 2023 Order, which granted respondent's Motion for Partial Summary Judgement concerning its compliance with the written supervisory approval requirements of section 6751(b)(1). In its motion, petitioner also requests that the Court establish a series of deadlines for the aforementioned hearing, which are different from the deadlines reflected in the Court's February 14, 2023 Order, setting forth the pretrial scheduling order in this case.
The pending motions are (1) petitioner's Motion for Reconsideration of Order filed on April 18, 2023, (2) petitioner's Motion to Impose Sanctions filed on April 18, 2023, and (3) respondent's Motion for Reconsideration of Order filed on April 19, 2023.
On May 18, 2023, a conference call with the parties was held. During the conference call, the parties requested a one-month extension of time to file responses to the pending motions, which, as per the Court's April 25, 2023 Order, are due on May 23, 2023. On May 19, 2023, respondent filed his Response to Motion to Set for a Time & Date Certain.
Upon due consideration of the foregoing, it is
ORDERED that respondent's responses to petitioner's Motion for Reconsideration of Order and Motion to Impose Sanctions filed on April 18, 2023, is extended to June 23, 2023. It is further
ORDERED that petitioner's response to respondent's Motion for Reconsideration of Order filed on April 19, 2023 is extended to June 23, 2023. It is further
ORDERED that petitioner's Motion to Set for a Time & Date Certain filed on May 15, 2023, is held in abeyance pending respondent's responses to petitioner's Motion for Reconsideration of Order and Motion to Impose Sanctions filed on April 18, 2023.