Opinion
26125-21
07-26-2024
MCKINLEY BROOKS, LLC, MCKINLEY BROOKS INVESTMENTS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris, Judge.
On July 17, 2024, petitioner filed a Motion for Partial Summary Judgment and a Memorandum in Support of Motion for Partial Summary Judgment, docket entries 73 and 74, respectively. Petitioner's Motion requests that the Court determine, as a matter of law, that the civil fraud penalty asserted under Internal Revenue Code section 6663 is inapplicable in this case.
After due consideration, it is
ORDERED that, on or before August 23, 2024, respondent shall file a response to petitioner's Motion for Partial Summary Judgment, filed July 17, 2024, docket entry 73.