Opinion
24703-21
02-21-2024
NORTH DONALD LA PROPERTY, LLC, NORTH DONALD LA INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
This case is calendared for trial at an initial special session of the Court beginning September 9, 2024, and a second special session beginning October 7, 2024, both in New Orleans, Louisiana. The case involves a charitable contribution deduction claimed by North Donald LA Property, LLC (NDLA). Respondent issued NDLA a notice of final partnership administrative adjustment (FPAA), disallowing this and other deductions and determining fraud and accuracy-related penalties.
On February 16, 2024, petitioner filed a Motion for Partial Summary Judgment seeking adjudication on the issue of the civil fraud penalty. Petitioner represents that respondent objects to the granting of the Motion.
In consideration of the foregoing, it is
ORDERED that respondent shall file with the Court, on or before March 13, 2024, a Response to petitioner's Motion for Partial Summary Judgment.