Opinion
20727-21
09-17-2024
MATTOCK HOLDINGS, LLC, ORNSTEIN-SCHULER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda, Judge
On March 12, 2024, the Court issued an Order setting out a pretrial schedule that shall be followed during pretrial preparation and trial for this case. [Doc. 48.] On August 23, 2024, petitioner filed a motion to amend Order for extension of time for petitioner to file dispositive motions. Petitioner requested that the Court extend the time for it to file dispositive motions until 14 days from the date that the Commissioner produces a complete copy of the administrative record of T.D. 8381 and certifies that it contains all documents and materials directly and indirectly considered by the agency, including all submitted comments to the proposed regulations. [Doc. 74.] Petitioner's motion states that the Commissioner does not object to the relief requested.
Upon due consideration, it is
ORDERED that petitioner's motion to amend Order for extension of time for petitioner to file dispositive motions is granted in that the due date in paragraph 2 of the Court's Order served March 12, 2024, shall be extended until 14 days from the date that the Commissioner produces a complete copy of the administrative record of T.D. 8381 and certifies that it contains all documents and materials directly or indirectly considered by the agency, including all submitted comments to the proposed regulations. It is further
ORDERED that all dates set out in the Court's pretrial scheduling Order served March 12, 2024, shall remain in full force and effect.