Opinion
19813-21
04-04-2024
ORION VALLEY, LLC, GREENCONE INVESTMENTS, LLC, TAX MATTERS PARTNER, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Christian N. Weiler Judge
On March 29, 2024, the parties filed a joint status report. In January of 2024, the parties to this case tried two cases with similar issues (Jackson Crossroads, LLC, et. al., Docket Nos. 12235-20 & 12249-20). Because of the similarity of issues with this case and the cases set for trial in January 2024, the parties agreed to pause discovery.
Respondent is in the process of transferring all docketed cases with Greencone Investments, LLC as the Tax Matter Partner to one set of attorneys in order to allow for a more uniform and efficient resolution of this and other cases with potentially overlapping issues.
Respondent has also commenced a settlement initiative in an attempt to resolve a certain group of cases that involve conservation easement deductions pursuant to I.R.C. § 170. This case is currently part of that settlement initiative. The parties believe that the most efficient way to move forward with this case is to wait until the settlement initiative is complete and all the cases with similar facts to this one in which the parties were unable to resolve pursuant to the settlement initiative have been identified.
Given due consideration to the foregoing, it is
ORDERED that on or before August 2, 2024, the parties shall file a joint status report outlining the then-present status of this case.