Opinion
11814-19
10-11-2022
OCONEE LANDING PROPERTY, LLC, OCONEE LANDING INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge
This case is calendared for trial at a two-week special session in Atlanta, Georgia, beginning November 14, 2022. On September 30, 2022, the parties filed a Motion to Seal, requesting that the Court seal (a) Exhibit C to respondent's May 5, 2022, Requests for Admissions (docket entry # 169), and (b) Exhibit 521-R to respondent's August 30, 2022, Motion for Order to Show Cause Why Proposed Facts and Evidence Should Not be Accepted as Established Pursuant to Rule 91(f) (docket entry #199).
The DAWSON database system does not enable the Court to seal a portion of a filing or to detach a portion of a filing and seal it separately. We will accordingly grant the Motion to Seal filed September 30, 2022, in that we will seal docket entries #169 and #199 and direct respondent to re-file, with confidential exhibits redacted, the contents of docket entries #169 and #199. Respondent shall separately lodge in unredacted form Exhibit C to respondent's May 5, 2022, Requests for Admissions, and Exhibit 521-R to respondent's August 30, 2022, Motion for Order to Show Cause, which the Court will then seal.
In consideration of the foregoing, it is
ORDERED that the joint Motion to Seal is granted in that the documents filed at docket entries #169 and #199 are sealed. It is further
ORDERED that respondent shall re-file, on or before October 14, 2022, the documents filed at docket entries #169 and #199 with confidential exhibits redacted. Respondent shall separately lodge unredacted versions of Exhibit C to respondent's May 5, 2022, Requests for Admissions, and Exhibit 521-R to respondent's August 30, 2022, Motion for Order to Show Cause.