Opinion
11814-19
02-09-2023
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 was tried at a seven-day special session in Atlanta, Georgia, from November 14 to 22, 2022. On March 8, 2022, the parties filed, at docket entries ## 130 and 134, documents containing, as attachments to the First Stipulation of Facts, Exhibits 1-J and 68-J through 72-J, respectively. On August 12, 2022, the parties filed, at docket entry # 186, a document containing, as attachments to the First Supplemental Stipulation of Facts, Proposed Trial Exhibits 126-R through 146-J. On September 30, 2022, the parties filed, at docket entry # 262, a document containing, as attachments to the Second Supplemental Stipulation of Facts, Proposed Trial Exhibits 265-R through 306-J.
During the first week of February 2023, the parties contacted the Court explaining that seven pages spread among docket entries ##130, 134, 186, and 262 should have been redacted in accordance with Tax Court Rule 27, and several Exhibits contained formatting errors. Accordingly, on February 7, 2023, the parties filed two First Amendments to Exhibit(s) consisting of Exhibits 1-J and 68-J through 72-J to the First Stipulation of Facts. That same day, the parties filed two First Amendments to Proposed Trial Exhibits consisting of Exhibits 126-R through 146-J to the First Supplemental Stipulation of Facts and Exhibits 265-R through 306-J to the Second Supplemental Stipulation of Facts. Each filing contains the properly redacted pages and corrected formatting.
Upon due consideration, it is
ORDERED that docket entries ## 130 and 134, consisting of Exhibits 1-J and 68-J through 72-J to the First Stipulation of Facts, respectively, are sealed and not made part of the Court's public record in this case. It is further
ORDERED that docket entry # 186, consisting of Proposed Trial Exhibits 126-R through 146-J to the First Supplemental Stipulation of Facts, is sealed and not made part of the Court's public record in this case. It is further
ORDERED that docket entry # 262, consisting of Proposed Trial Exhibits 265-R through 306-J to the Second Supplemental Stipulation of Facts, is sealed and not made part of the Court's public record in this case.
The sealed documents shall be retained by the Court in sealed files which shall not be opened for inspection by any person or entity except by Order of the Court.