Opinion
26125-21
06-14-2023
MCKINLEY BROOKS, LLC, MCKINLEY BROOKS INVESTMENTS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Elizabeth Crewson Paris Judge.
This case was previously calendared for trial at the Court's January 30, 2023, Birmingham, Alabama Trial Session and by Joint Motion for Continuance, this case was continued with jurisdiction retained by this Division of the Court, by Order dated December 12, 2022, docket entry 12.
On January 27, 2023, the parties filed a First Stipulation of Facts, consisting of paragraphs 1 through 19, with attached Exhibits 1-J - 6-J, (Part 1) at docket entry 17, and Exhibits 7-J -13-J, (Part 2 Continued) at docket entry 18.
On June 2, 2023, respondent filed (1) a Motion for Partial Summary Judgment; (2) a Memorandum in Support of Motion for Partial Summary Judgment; and (3) a Declaration of Richard L. Wooldridge in Support of Motion for Partial Summary Judgment, docket entries 23, 24, and 25 respectively.
After due consideration, and for cause, it is
ORDERED that, on or before July 21, 2023, petitioner shall file a response to respondent's Motion for Partial Summary Judgment, filed June 2, 2023, docket entry 23.