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 August 23, 2024, petitioner filed a motion to compel production of documents requesting the Court enter an Order directing the Commissioner (i) to produce to petitioner, within 14 days, a complete copy of the administrative record of T.D. 8381 and (ii) to certify that it contains all documents and materials directly or indirectly considered by the agency, including all submitted comments to the proposed regulations. [Doc. 73.] This motion indicates that the Commissioner objects to the granting of this motion. We will direct the Commissioner to file a response. Accordingly, it is
ORDERED that, on or before October 8, 2024, the Commissioner shall file a response to the petitioner's above-referenced motion to compel production of documents.