Opinion
9620-21 13346-21
09-23-2024
MURPHY HOLLOW, LLC, PIEDMONT PRIVATE EQUITY MANAGER, LLC, TAX MATTERS PARTNER, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Patrick J. Urda, Judge
During the Court's remote trial proceeding on September 17, 2024, the Commissioner orally moved for leave to file out of time a motion for reconsideration of Order served August 16, 2024. Upon due consideration and for cause more fully appearing in the transcript of the proceeding, it is
ORDERED that the Commissioner's oral motion for leave to file out of time a motion for reconsideration of Order is granted, and the Commissioner may move for reconsideration of our Order in his posttrial briefing. Petitioners shall also address these points in their posttrial briefing.