Opinion
11814-19
10-19-2022
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. By Order dated October 11, 2022, we granted the parties' motion to seal 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. We directed respondent to re-file the relevant documents in the manner we prescribed in the Order. Later that day, respondent filed documents bearing the cover pages First Amended First Request for Admissions at docket entries #290 and #291, Redacted Exhibit(s) to Proposed Second Supplemental Stipulation of Facts (440-R through 524) at docket entry #292, and First Amended Exhibit(s) at docket #293. These documents appear in substance to be the documents we directed respondent to re-file in our October 11, 2022, Order.
In consideration of the foregoing and for cause, it is
ORDERED that the document filed at docket entry #290 shall be recharacterized as "Respondent's First Request for Admissions (redacted)." It is further
ORDERED that the document filed at docket entry #291 shall be recharacterized as "Exhibit C to Respondent's First Request for Admissions (unredacted)" and sealed. This sealed document shall not be inspected by any person or entity except by an Order of the Court.
ORDERED that the document filed at docket entry #292 shall be recharacterized as "Exhibits to Respondent's Motion for Order to Show Cause (redacted)." It is further
ORDERED that the document filed at docket entry #293 shall be recharacterized as "Exhibit 521-R to Respondent's Motion for Order to Show Cause (unredacted)" and sealed. This sealed document shall not be inspected by any person or entity except by an Order of the Court.