Opinion
11814-19
03-26-2024
OCONEE LANDING PROPERTY, LLC, OCONEE LANDING INVESTORS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Albert G. Lauber Judge.
On February 21, 2024, the Court filed its Memorandum Opinion (T.C. Memo. 2024-25). On March 22, 2024, respondent filed a Motion for Reconsideration of Findings or Opinion Pursuant to Rule 161, limited to one issue-the proper treatment of the negligence penalty. In consideration of the foregoing, it is
ORDERED that, on or before April 24, 2024, petitioner shall file a Response to respondent's Motion for Reconsideration of Findings or Opinion Pursuant to Rule 161. It is further
ORDERED that, on or before May 8, 2024, respondent may file, if he wishes, a Reply to petitioner's Response.