Opinion
9620-21 13346-21
09-04-2024
MURPHY HOLLOW, LLC, PIEDMONT PRIVATE EQUITY MANAGER, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda, Judge
Per the Court's Order served September 19, 2023, setting forth a pretrial schedule for the trial of these cases, the Court directed that, inter alia, that the last date to file unagreed proposed trial exhibits, other than impeachment evidence is August 29, 2024.
On August 30, 2024, the Commissioner filed a motion to strike requesting that the Court strike from the record in these cases some proposed trial exhibits and declarations filed on August 29, 2024, that inadvertently omitted some redactions. The Commissioner refiled those same documents containing the proper redactions on August 30, 2024. We will grant the motion to strike. Accordingly, it is
ORDERED that the Commissioner's motion to strike is granted and the following documents shall be deemed stricken from the Court's record in these cases and shall be placed under seal, thus rendered not reviewable as part of these cases:
• Commissioner's proposed trial exhibits (Exhibits 151-R to 365-R) filed August 29, 2024;
• Commissioner's declaration of Leah Hollifield in support of proposed trial Exhibits 351-R to 357-R;
• Commissioner's declaration of William Camacho in support of proposed Trial Exhibits 345-R to 349-R filed August 29, 2024; and
• Commissioner's proposed trial exhibits (Exhibits 2131-R to 2160-R) filed August 29, 2024.