Opinion
20727-21
07-31-2024
MATTOCK HOLDINGS, LLC, ORNSTEIN-SCHULER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda Judge.
On July 15, 2024, the Court issued an Order granting in part petitioner's motion to compel production of documents and directed the Commissioner to produce the administrative record of T.D. 8381 within three weeks. The Commissioner filed a motion for extension of time on July 30, 2024, requesting additional time to file the administrative record. The Commissioner further notes in his motion that petitioner may file a motion for summary judgment that relies on the administrative record but may need an extension to do so if we grant the Commissioner's motion for extension of time to produce the administrative record. Should the petitioner need additional time, it may file a motion for the Court to consider.
Upon due consideration, it is
ORDERED that the Commissioner's motion for extension of time is granted, and the time in which the Commissioner shall produce the administrative record of T.D. 8381 is now extended until August 19, 2024.