Opinion
5131-19 5132-19 5133-19 5134-19 5135-19 5136-19 22809-22 22921-22 22922-22 22924-22 22954-22 22956-22
09-18-2024
PCMG TRADING PARTNERS XII, LP, DANNY E. PETTIT, TAX MATTERS PARTNER, ET AL., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent
ORDER
Mark V. Holmes, Judge.
The lower-numbered six of these cases were on the March 6, 2023 Dallas trial calendar. Six later cases were then assigned to this division of the Court and the place of trial was changed to Houston. We got all 12 cases on the same status-report track, as the parties previously reported that they have settled in principle and had begun drafting closing agreements.
The parties recently reported that given the complexity of the agreed settlements, the process of drafting, reviewing, and executing the Form 906 closing agreements to implement them will take additional time. Once these closing agreements are executed, these cases can be dismissed since all items will have then converted to non-partnership items.
They reasonably suggest reporting again at the end of October if they haven't finished this drafting, and it is
ORDERED that on or before October 30, 2024 the parties shall submit settlement documents or file a status report to update the Court as to the status of the Form 906 closing agreements.